United States securities and exchange commission logo

                             September 4, 2020

       George Goldsmith
       Chief Executive Officer
       Compass Rx Ltd.
       COMPASS Rx Limited
       3rd Floor
       1 Ashley Road
       Cheshire WA14 2DT
       United Kingdom

                                                        Re: Compass Rx Ltd.
Statement on Form F-1
                                                            Filed August 28,
                                                            File No. 333-248484

       Dear Mr. Goldsmith:

              We have reviewed your 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 amending your registration
statement and providing the
       requested information. 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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1

       Drug Discovery Center, page 170

   1.                                                   Please revise to
disclose the aggregate future milestone payments and the royalty term
                                                        under your sponsored
research agreement with the University of the Sciences. We note
                                                        your disclosure that
the agreement terminates, unless terminated earlier, on the expiration
                                                        or revocation of the
last valid claim of any patent included in the joint intellectual
                                                        property. Please
specify when the licensed patents are currently expected to expire. Please
                                                        also file this
agreement as an exhibit or tell us why you do not believe it is required.
 George Goldsmith
Compass Rx Ltd.
September 4, 2020
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

        You may contact Kristin Lochhead at (202) 551-3664 or Angela Connell at
(202) 551-
3426 if you have questions regarding comments on the financial statements and
related matters.
Please contact Ada Sarmento at (202) 551-3798 or Joe McCann at (202) 551-6262
with any
other questions.

FirstName LastNameGeorge Goldsmith
                                                           Division of
Corporation Finance
Comapany NameCompass Rx Ltd.
                                                           Office of Life
September 4, 2020 Page 2
cc:       Benjamin K. Marsh, Esq.
FirstName LastName