United States securities and exchange commission logo

                             August 22, 2022

       Vlad Couric, M.D.
       Chief Executive Officer
       Biohaven Research Ltd.
       215 Church Street
       New Haven, CT 06510

                                                        Re: Biohaven Research
Statement on Form 10
                                                            Filed August 10,
                                                            File No. 001-41477

       Dear Dr. Couric:

              We have reviewed your filing 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

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Registration Statement on Form 10 filed August 10, 2022

       Exhibit 99.1
       Questions and Answers about the Separation and Distribution
       Q: What conditions must be satisfied to complete the Spin-Off?, page 3

   1.                                                   We note your response
to prior comment 1 and reissue in part. Please revise to clarify that
                                                        you may not waive the
condition of "no legal restraint" against the Separation, Merger or
                                                        Distribution, or
advise. Please also identify any other conditions which the parties would
                                                        be unable to waive.
 Vlad Couric, M.D.
FirstName LastNameVlad
Biohaven Research Ltd. Couric, M.D.
August 22, NameBiohaven
           2022         Research Ltd.
Page 2 22, 2022 Page 2
FirstName LastName
Intellectual Property
License Agreements, page 100

2.       We note your response to prior comment 10. Please revise this section
to separately
         disclose the aggregate potential milestone payments to be paid or
received under each
         material licensing agreement.
        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.

       You may contact Julie Sherman at 202-551-3640 or Mary Mast at
202-551-3613 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tyler Howes at 202-551-3370 or Jason Drory at 202-551-8342 with any
other questions.


                                                             Division of
Corporation Finance
                                                             Office of Life
cc:      Robert Downes, Esq.