January 6, 2020

Joerg Hornstein
Chief Financial Officer
AC Immune SA
EPFL Innovation Park
Building B
1015 Lausanne
Switzerland

       Re: AC Immune SA
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed April 19, 2019
           Form 6-K for the Quarterly Period Ended June 30, 2019
           Filed August 14, 2019
           File No. 001-37891

Dear Mr. Hornstein:

        We have reviewed your December 20, 2019 response to our comment letter
and have the
following comment. In our comment we may ask you to provide us with information
so we may
better understand your disclosure.

       Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

     After reviewing your response to the comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
December 4, 2019 letter.

Form 6-K dated August 14, 2019

Exhibit 99.1
Interim Condensed Financial Statements (Unaudited)
Notes to Interim Condensed Financial Statements
3.1 Licensing and collaboration agreements, page 13

1.    We acknowledge the information provided in your response to comment 1.
Please revise
      your disclosure to include the significant judgments underlying your
conclusion that the
      license granted to Lilly was distinct and represented a right-to-use, as
addressed in IFRS
 Joerg Hornstein
AC Immune SA
January 6, 2020
Page 2
         15.123 and 125. In this regard, consider providing certain information
on pages 2-5 of
         your response, as follows:
           The nature of the license granted to Lilly with regard to its
ongoing development and
             future commercialization activities,
           The degree to which the Pre-clinical and Phase 1 development
activities conducted
             by you "do not represent integrated services with the licensed IP"
to Lilly and the
             absence of any impact of your R&D activities on the "form or
functionality of the
             underlying IP" licensed to Lilly,
           The purpose of Pre-clinical and Phase 1 development activities
conducted by Lilly
             and the absence of any linkage between these activities and your
development
             activities, other than through the joint steering committee and
           The nature and frequency of the information-sharing process through
the joint
             steering committee and how this process is expected to impact the
future
             development activities to be independently conducted by you and
Lilly.

       You may contact Ibolya Ignat at (202) 551-3636 or Franklin Wyman at
(202) 551-3660
with any questions.



FirstName LastNameJoerg Hornstein                           Sincerely,
Comapany NameAC Immune SA
                                                            Division of
Corporation Finance
January 6, 2020 Page 2                                      Office of Life
Sciences
FirstName LastName