United States securities and exchange commission logo October 14, 2020 James Parslow Chief Financial Officer Xenetic Biosciences, Inc. 40 Speen Street, Suite 102 Framingham, Massachusetts 01701 Re: Xenetic Biosciences, Inc. Preliminary Proxy Statement on Schedule 14A Filed September 30, 2020 File No. 001-37937 Dear Mr. Parslow: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Caitlin Simkins