United States securities and exchange commission logo

                             January 5, 2021

       Owen Hughes
       President and Chief Executive Officer
       Cullinan Oncology, LLC
       One Main Street
       Suite 520
       Cambridge, MA 02142

                                                        Re: Cullinan Oncology,
                                                            Amendment No. 2 to
Registration Statement on From S-1
                                                            Filed January 4,
                                                            File No. 333-251512

       Dear Mr. Hughes:

              We have reviewed your registration statement and have the
following comment. In our
       comment, we may ask you to provide us with information so we may better
understand your

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies 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 this comment, we may have additional comments.

       Amendment No. 2 to Registration Statement on Form S-1

       Notes to Condensed Consolidated Financial Statements
       (13) Subsequent Events, page F-51

   1.                                                   You disclose on page
F-32 that the board of directors determined that the fair market
                                                        value of a common stock
unit would be $0.61. Please update your disclosure to clarify that
                                                        the retrospective
valuation as of October 30, 2020 increased the fair value of a common
                                                        unit to $1.16, as well
as the extent to which such amounts are pre-split versus post-split.
                                                        Revise this note or
elsewhere in your document as appropriate to quantify the amount of
                                                        the stock compensation
expense you expect to recognize for these equity instruments in
 Owen Hughes
Cullinan Oncology, LLC
January 5, 2021
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 Vanessa Robertson at 202-551-3649 or Kevin Vaughn at
if you have questions regarding comments on the financial statements and
matters. Please contact Laura Crotty at 202-551-7614 or Suzanne Hayes at
202-551-3675 with
any other questions.

FirstName LastNameOwen Hughes
                                                           Division of
Corporation Finance
Comapany NameCullinan Oncology, LLC
                                                           Office of Life
January 5, 2021 Page 2
cc:       Gabriela Morales-Rivera
FirstName LastName