February 11, 2020

Mark Dybul
Executive Vice Chair
Enochian Biosciences Inc
2080 Century Park East, Suite 906
Los Angeles, CA 90067

       Re: Enochian Biosciences Inc
           Form 10-K for the fiscal year ended June 30, 2019
           Filed September 30, 2019
           File No. 001-38758

Dear Mr. Dybul:

      We have reviewed your filing 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 comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for the fiscal year ended June 30, 2019

Note 3--Acquisition of Enochian Biopharma, page F-15

1.    In your Form 10-Q for the quarterly period ended March 31, 2018, in which
you first
      accounted for the acquisition of Enochian Biosciences, you valued the
shares issued as
      consideration at their closing price on that date, which was $5.20 per
share. However, in
      subsequent filings, including your Forms 10-K for the years ended June
30, 2018 and
      2019, you valued these shares at $8.00 per share. This revised valuation
resulted in a
      $38.7 million increase to the total transaction consideration and
intangible assets recorded
      as part of the acquisition (primarily consisting of IPR&D).You indicate
that this revised
      valuation was based on the last third party private placement for cash
which occurred at or
      around the acquisition date due to a lack of trading volume in your
stock. Please explain to
      us how you considered the guidance in ASC 820 in determining that the
price indicated by
      a recent third party private placement was more indicative of the fair
value of your
      common stock than the reported closing price on the transaction date. In
this regard, tell us
      how you assessed whether your stock trades in an active market. Please
also explain how
 Mark Dybul
Enochian Biosciences Inc
February 11, 2020
Page 2
         you considered the factors in ASC 820-10-35-54C in assessing the
volume of trading
         activity in your common stock.

        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.

       You may contact Frank Wyman at (202) 551-3660 or Ibolya Ignat at (202)
551-3636 with
any questions.



FirstName LastNameMark Dybul                                Sincerely,
Comapany NameEnochian Biosciences Inc
                                                            Division of
Corporation Finance
February 11, 2020 Page 2                                    Office of Life
Sciences
FirstName LastName