October 25, 2024

James F. Parslow
Interim Chief Executive Officer and Chief Financial Officer
Xenetic Biosciences, Inc.
945 Concord Street
Framingham, Massachusetts 01701

       Re: Xenetic Biosciences, Inc.
           Registration Statement on Form S-3
           Filed October 21, 2024
           File No. 333-282756
Dear James F. 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 Chris Edwards at 202-551-6761 with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences
cc:   Danielle C. Price