United States securities and exchange commission logo October 19, 2021 James Parslow Chief Financial Officer Xenetic Biosciences, Inc. 40 Speen Street, Suite 102 Framingham, Massachusetts 01701 Re: Xenetic Biosciences, Inc. Registration Statement on Form S-3 Filed on October 12, 2021 File No. 333-260201 Dear Mr. Parslow: This is to advise you that we have not reviewed and will not review your registration statement. 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 Jessica Ansart at (202) 551-4511 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Danielle Price