July 27, 2021


U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549



Tracey McKoy

Kevin Kuhar

Kasey Robinson

Laura Crotty



Rani Therapeutics Holdings, Inc.

Registration Statement on Form S-1

Submitted July 9, 2021, as amended

File No. 333-257809

Acceleration Request

Requested Date: July 29, 2021

Requested Time: 4:00 p.m., Eastern Daylight Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), BofA Securities, Inc., Stifel, Nicolaus & Company, Incorporated, Cantor Fitzgerald & Co. and Canaccord Genuity LLC, as representatives of the several underwriters, hereby join Rani Therapeutics Holdings, Inc. in requesting that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the Registration Statement on Form S-1 (File No. 333-257809) (the “Registration Statement”) to become effective on July 29, 2021, at 4:00 p.m., Eastern Daylight Time, or as soon as practicable thereafter.

Pursuant to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement.

We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, to the extent applicable.

[Signature Page Follows]

Very truly yours,
BofA Securities Inc.

/s/ Michael Liloia

Name:   Michael Liloia
Title:   Director
Stifel, Nicolaus & Company, Incorporated

/s/ Nathan Thompson

Name:   Nathan Thompson
Title:   Director
Cantor Fitzgerald & Co.

/s/ Sage Kelly

Name:   Sage Kelly
Title:   Head of Investment Banking
Canaccord Genuity LLC

/s/ Eugene Rozelman

Name:   Eugene Rozelman
Title:   Managing Director



Talat Imran, Rani Therapeutics Holdings, Inc.

Edwin M. O’Connor, Goodwin Procter LLP

Deepa M. Rich, Goodwin Procter LLP

Shoaib A. Ghias, Goodwin Procter LLP

Josh Seidenfeld, Cooley LLP

Mark B. Weeks, Cooley LLP

[Signature Page to Acceleration Request]