United States securities and exchange commission logo

                              July 6, 2021

       Mir Imran
       President and Chief Executive Officer
       Rani Therapeutics Holdings, Inc.
       2051 Ringwood Avenue
       San Jose, CA 95131

                                                        Re: Rani Therapeutics
Holdings, Inc.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 22,
                                                            CIK No. 0001856725

       Dear Mr. Imran:

              We have reviewed your amended draft registration statement and
have the following
       comment. In our comment 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 comment applies 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 this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted
June 22, 2021

       Intellectual Property, page 168

   1.                                                   We note the revised
disclosure provided in response to our prior comment 14 and we
                                                        reissue the comment in
part. In relation to the company's material patents, please further
                                                        revise your
intellectual property disclosure to clearly describe on an individual or patent
                                                        family basis the type
of patent protection granted for each product or technology
                                                        (composition of matter,
use, or process), the expiration year of each patent, and the
                                                        jurisdiction, including
any foreign jurisdiction, of each material pending or issued patent.
                                                        In this regard, it may
be useful to provide this disclosure in tabular form to support the
 Mir Imran
Rani Therapeutics Holdings, Inc.
July 6, 2021
Page 2
      narrative already included.
       You may contact Kevin Kuhar at 202-551-3662 or Tracey McKoy at
202-551-3772 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Lauren Hamill at 303-844-1008 or Laura Crotty at 202-551-7614 with any

FirstName LastNameMir Imran
                                                          Division of
Corporation Finance
Comapany NameRani Therapeutics Holdings, Inc.
                                                          Office of Life
July 6, 2021 Page 2
cc:       Josh Seidenfeld
FirstName LastName