February 4, 2019

Jean-Fran ois Mouney
Chief Executive Officer
Genfit S.A.
Parc Eurasant
885, avenue Eug ne Avin e
59120 Loos, France

       Re: Genfit S.A.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted December 21, 2018
           CIK No. 0001757064

Dear Mr. Mouney:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
December 12, 2018 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1

Business
Our Clinical Program for Elafibranor in the Treatment of NASH
Golden - 505--Our Phase 2b Clinical Trial
Safety Results, page 109

1.     We note your response to comment 13. Please identify the specific
serious adverse events
       that occurred in your clinical trials of Elafibranor.
 Jean-Fran ois Mouney
Genfit S.A.
February 4, 2019
Page 2
Our Drug Candidates and Diagnostic Development Programs
Nitazoxanide Program for the Treatment of Fibrosis
Pre-clinical and Clinical Development Program, page 123

2.       We note your response to comment 12. Please disclose the range of
results measured in
         each cohort. In this regard, we note that you have provided only the
average results.
         Similarly, on page 115, you state that "[t]he mice in the combination
therapy group
         experienced a statistically significant attenuation of liver fibrosis
of 52%, compared to
         36% in the group receiving only elafibranor and 27% in the group
receiving only NTZ,
         each as compared to the CDAA/c only group." Please disclose the range
of attenuation of
         liver fibrosis observed in each of the categories as well as the
number of mice that
         experienced such results. In addition, we note your disclosure on page
115 that "[i]n the
         combination therapy group, hepatic collagen was reduced by 41%,
compared to 22% in
         the group receiving only elafibranor and 23% in the group receiving
only NTZ, each as
         compared to the CDAA/c only group." Please disclose the range of
results as well as the
         number of mice that experienced these results.
TGFTX1 Program for the Treatment of IL-17-Dependent Autoimmune Diseases , page
124

3.       We note your response to comment 18 . To provide context for the scale
of the trial,
         please disclose the number of mice tested in your preclinical trial of
TGFTX1 disclosed
         on page 125.
        You may contact Vanessa Robertson at 202-551-3649 or Lisa Vanjoske at
202-551-3614
if you have questions regarding comments on the financial statements and
related
matters. Please contact Sonia Bednarowski at 202-551-3666 or Dietrich King at
202-551-8071
with any other questions.



FirstName LastNameJean-Fran ois Mouney                       Sincerely,
Comapany NameGenfit S.A.
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Corporation Finance
February 4, 2019 Page 2                                      Office of
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