April 9, 2020

William Hinshaw
Chief Executive Officer
Axcella Health Inc.
840 Memorial Drive
Cambridge, MA 02139

       Re: Axcella Health Inc.
           Draft Registration Statement on Form S-1
           Filed April 3, 2020
           CIK No. 0001633070

Dear Mr. Hinshaw:

       This is to advise you that we do not intend to review your registration
statement.

        We request that you publicly file your registration statement no later
than 48 hours prior
to the requested effective date and time. 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 Paul Fischer at 202-551-3415 with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Life
Sciences
cc:    Laurie Burlingame, Esq.