United States securities and exchange commission logo

                             July 17, 2020

       Nello Mainolfi, Ph.D.
       President and Chief Executive Officer
       Kymera Therapeutics, Inc.
       300 Technology Square, 2nd Floor
       Cambridge, MA 02139

                                                        Re: Kymera
Therapeutics, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 22,
                                                            CIK No. 0001815442

       Dear Dr. Mainolfi:

              We have reviewed your draft registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form S-1

       Prospectus Summary
       Overview, page 1

   1.                                                   Define or explain these
terms the first time you use them in the document:
                                                            "IL-1R/TLR" and
"JAK/STAT" (page 1);
                                                            "E3 ligase" (page
suppurativa" (page 3);
                                                            "JAKs" (page 3);
                                                            PK/PD modeling
(page 4);
                                                               cereblon and von
Hippel-Lindau, or VHL    (at pages 100, 103); and
                                                            TPD (page 105).
 Nello Mainolfi, Ph.D.
FirstName  LastNameNello
Kymera Therapeutics,  Inc. Mainolfi, Ph.D.
July       NameKymera Therapeutics, Inc.
     17, 2020
July 17,
Page  2 2020 Page 2
FirstName LastName
2.       Your pipeline appears to include every in-house development program as
well as the
         program you have licensed to Vertex. Please revise the table to
include only those
         programs that are material to the company. If you believe that every
program listed is
         material, please provide us an analysis explaining your belief. To the
extent the Pegasus
         Platform remains in your table, revise the disclosure to correspond to
the appropriate
         column of development.
3.       Please revise your table to include columns showing the various
material phases of the
         development of your potential products, including, as applicable,
discovery, preclinical,
         development and the various phases of clinical development. Also
include an arrow
         indicating the phase each of your product candidates is in for the
various stages of
         development for each indicated disease area.
4.       You mention in your summary and highlight in the pipeline table that
other potential
         targets for your KT-474 product, which is the farthest product you
have in development,
         are atopic dermatitis (AD) and rheumatoid arthritis (RA). You also
state, however, that
         your product is not targeting these indications. As such, revise your
summary and
         pipeline table to remove these references or provide your analysis of
why they are
         material and appropriate for disclosure here.
Our IRAK4, IRAKIMiD, and STAT3 Programs, page 3

5.       Please revise your statements on pages 3, 125 and elsewhere in the
prospectus that certain
         of your product candidates are    first-in-class.    These statements
imply an expectation of
         regulatory approval and are inappropriate given the length of time and
uncertainty with
         respect to securing marketing approval.
6.       For KT-474 and IRAKIMiD you state you will submit an IND and initiate
phase 1 trial in
         first half of 2021, and for IRAKIMiD, you state you expect to do both
in the second half
         of 2021. As you have more control over when you submit the IND, revise
to clarify when
         you expect that to occur for each product.
Corporate Information, page 6

7.       Please provide us with copies of all written communications, as
defined in Rule 405 under
         the Securities Act, that you, or anyone authorized to do so on your
behalf, present to
         potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they
         retain copies of the communications.
Risk Factors
Risks Related to Intellectual Property, page 43

8.       We note the risk factor on page 46 related to objections to the name
Kymera and Kymera
         Therapeutics. You disclose that "If we are unable to obtain a
registered trademark or
         establish name recognition based on our trademarks and trade names, we
may not be able
         to compete effectively and our business may be adversely affected." Is
it also true that
 Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
July 17, 2020
Page 3
         you could be forced to change your name and incur additional
significant related
         expenses? Revise the risk factor to further disclose the potential
material risks.
9.       On page 53, you disclose that "the Leahy-Smith Act has transformed the
U.S. patent
         system into a    first inventor to file    system. The
first-inventor-to-file provisions, however,
         only became effective on March 16, 2013. Accordingly, it is not yet
clear what, if any,
         impact the Leahy-Smith Act will have on the operation of our
business." (Emphasis
         Added). As your company was first incorporated in December 2015,
clarify why the Act's
         application to you remains unclear.
Use of Proceeds, page 70

10.      You state the proceeds will be used for the "advancement" of each of
your products.
         Please expand your disclosure regarding the proceeds to be used for
your product
         candidates to describe how far in the development process you estimate
the allocated
         proceeds from this offering will enable you to reach.
Management's Discussion and Analysis of Financial Condition and Results of
Components of Our Results of Operations, page 83

11.      It appears from page F-24 you have a collaboration agreement with an
entity other than
         Vertex, or a prior, separate collaboration agreement with Vertex.
Revise to disclose that
         collaboration or provide your analysis why disclosure is not required.
Critical Accounting Policies and Estimates
Determination of the Fair Value of Common Stock, page 94

12.      Once you have an estimated offering price or range, please explain to
us how you
         determined the fair value of the common stock underlying your equity
issuances and the
         reasons for any differences between the recent valuations of your
common stock leading
         up to the IPO and the estimated offering price. This information will
help facilitate our
         review of your accounting for equity issuances including stock
compensation and
         beneficial conversion features.
Overview, page 97

13.    Here and on pages 103 and 104 you refer to "potent activity" of your
potential degraders,
       your "highly efficient, selective and potent degraders" with
"appropriate pharmaceutical
FirstName LastNameNello Mainolfi, Ph.D.
       properties" and "potent and specific degraders." Given the stage of your
Comapany   NameKymera
       development,        Therapeutics,
                     it appears  prematureInc.
                                            to describe your product candidates
as potent, which
       implies they
July 17, 2020 Page 3are effective.  Please revise or advise why this disclosure
is appropriate.
FirstName LastName
 Nello Mainolfi, Ph.D.
FirstName  LastNameNello
Kymera Therapeutics,  Inc. Mainolfi, Ph.D.
July       NameKymera Therapeutics, Inc.
     17, 2020
July 17,
Page  4 2020 Page 4
FirstName LastName
Our Strategy, page 99

14.      Given the current state of development of your product candidates, it
is unclear if you
         have a basis for your statements that you have    industry-leading
expertise" (at page 99
         and 137) and "significant competitive advantages" and    dominant
intellectual property
         position (at page 137). Please clarify.
15.      Revise Figures 8-10 and 18 to better explain what each depicts. For
Figures 8-9 in
         particular, the point of the graphics are unclear beyond reinforcing
your product by
16.      On page 113, you defined hPMBC. Then, starting on page 117 and going
forward, you
         identify the generic word    blood    as PMBC. Please clarify any
17.      We note the blog and press release on your website related to the
findings reported at the
         American Association of Cancer Research virtual meeting held June 22,
2020, the date of
         this registration statement. To the extent you have not done so,
revise the document to
         include material information included on your website.
Collaborations, page 136

18.      On your website you list several    Academic Collaborators
including Yale, Columbia,
         New York University and the Dana-Farber Cancer Institute, and
Partners,    including
         GlaxsoSmithKline, Vertex and the Leukemia & Lymphoma Society. Only the
         agreement is discussed here. Advise us of your collaborations or
partnerships with these
         entities and provide your analysis regarding whether they are required
to be disclosed
19.      Revise to disclose your collaboration with Sanofi as discussed in your
July 9, 2020 press
         release. Avoid use of the term    first-in-class," used in the press
release, for the reasons
         cited above.
Intellectual Property, page 138

20.      Revise the paragraph addressing "Target-Specific Degrader Patent
Families" to disclose
         the number of patents and their location. Revise this section to
clarify whether you own
         or license the patents disclosed, clarify the types of patents you
have, and identify the
         jurisdictions in which you have foreign patents. We note some of this
disclosure in the
         risk factor on page 43.
Facilities, page 156

21.      You disclose in the notes of the financial statements that you
terminated a lease effective
         July 31, 2020. It appears that is the Cambridge lease, as the lease
you have included as an
         exhibit extends until May 2023. You state you    lease and expect to
occupy    the property
         in Watertown. Revise your disclosure in this section to clarify your
current and expected
         facilities. Refer to Item 102 of Regulation S-K
 Nello Mainolfi, Ph.D.
Kymera Therapeutics, Inc.
July 17, 2020
Page 5
Executive Compensation
Employment Agreements with our Named Executive Officers, page 169

22.      File the employment agreements with each of the named executive
officers as required by
         Item 601(b)(10) of Regulation S-K.
Certain Relationships and Related Party Transactions, page 182

23.      File the Vertex Participation Agreement as an exhibit. Refer to Item
601(b)(10) of
         Regulation S-K.
Description of Capital Stock
Choice of Forum, page 193

24.      Here you state, that your "choice of forum provision does not apply to
any causes of
         action arising under the Securities Act or the Exchange Act." in the
risk factor on page
         62, however, you state, "The Delaware Forum Provision will not apply
to any causes of
         action arising under the Securities Act or the Exchange Act," but then
state, "the United
         States District Court for the District of Massachusetts shall be the
sole and exclusive
         forum for resolving any complaint asserting a cause of action arising
under the Securities
         Act," calling that the "Federal Forum Provision." We note that Section
22 of the
         Securities Act creates concurrent jurisdiction for federal and state
courts over all suits
         brought to enforce any duty or liability created by the Securities Act
or the rules and
         Regulations thereunder, and Section 27 of the Exchange Act creates
exclusive federal
         jurisdiction over all suits brought to enforce any duty or liability
created by the Exchange
         Act or the rules and regulations thereunder. Clarify whether there are
forum restrictions
         for Exchange Act claims.
        You may contact Vanessa Robertson at (202) 551-3649 or Daniel Gordon at
(202) 551-
3486 if you have questions regarding comments on the financial statements and
matters. Please contact Abby Adams at (202) 551-6902 or Celeste Murphy at (202)
3257 with any other questions.

FirstName LastNameNello Mainolfi, Ph.D.                        Sincerely,
Comapany NameKymera Therapeutics, Inc.
                                                               Division of
Corporation Finance
July 17, 2020 Page 5                                           Office of Life
FirstName LastName