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                             December 21, 2023

       Yajing Chen
       Chief Financial Officer
       Zai Lab Ltd
       4560 Jinke Road
       Bldg. 1, Fourth Floor
       Pudong, Shanghai, China 201210

                                                        Re: Zai Lab Ltd
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Response dated
December 4, 2023
                                                            File No. 001-38205

       Dear Yajing Chen:

              We have reviewed your December 4, 2023 response to our comment
letter and have the
       following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our November 17,
       2023 letter.

       Form 10-K for Fiscal Year Ended December 22, 2022

       Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 158

   1.                                                   We note your statement
that you reviewed public filings, material contracts and director
                                                        and officer
questionnaires in connection with your required submission under paragraph
                                                        (a). Please
supplementally describe any additional materials that were reviewed and tell
                                                        us whether you relied
upon any legal opinions or third party certifications such as
                                                        affidavits as the basis
for your submission. In your response, please provide a similarly
                                                        detailed discussion of
the materials reviewed and legal opinions or third party
                                                        certifications relied
upon in connection with the required disclosures under paragraphs
                                                        (b)(2) and (3).
   2.                                                   In order to clarify the
scope of your review, please supplementally describe the steps you
 Yajing Chen
Zai Lab Ltd
December 21, 2023
Page 2
      have taken to confirm that none of the members of your board or the
boards of your
      consolidated foreign operating entities are officials of the Chinese
Communist Party. For
      instance, please tell us how the board members    current or prior
memberships on, or
      affiliations with, committees of the Chinese Communist Party factored
into your
      determination. In addition, please tell us whether you have relied upon
third party
      certifications such as affidavits as the basis for your disclosure.
       Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at
202-551-3377 with
any other questions.



                                                          Sincerely,
FirstName LastNameYajing Chen
                                                          Division of
Corporation Finance
Comapany NameZai Lab Ltd
                                                          Disclosure Review
Program
December 21, 2023 Page 2
cc:       Aslynn Hogue
FirstName LastName