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                                                            June 20, 2025

Datuk Dr. Doris Wong
Chief Executive Officer
Cyclacel Pharmaceuticals, Inc.
Level 10, Tower 11, Avenue 5, The Horizon
Bangsar South City, No. 8, Jalan Kerinchi, 59200
Kuala Lumpur, Malaysia

       Re: Cyclacel Pharmaceuticals, Inc.
           Draft Registration Statement on Form S-4
           Submitted on June 16, 2025
           CIK No. 0001130166
Dear Datuk Dr. Doris Wong:

       This is to advise you that we do not intend to review your registration
statement.

       We request that you publicly file your registration statement at least
two business
days prior to the requested effective date and time. Please refer to Rules 460
and 461
regarding requests for acceleration. We remind you that the company and its
management are
responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review,
comments, action or absence of action by the staff.

       Please contact Chris Edwards at 202-551-6761 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Debbie A. Klis, Esq.
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