December 4, 2019

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

       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 limited our review of your filing to the financial statements
and related
disclosures 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 this comment within ten business days by providing the
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

       After reviewing your response to the comment, we may have additional

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.    Please provide us the following information supporting your revenue
recognition for the
      license granted under the collaboration agreement with Eli Lilly and
Company ("Lilly").
        Explain the factors that you considered in characterizing this license
transferred to
           Lilly as a distinct performance obligation representing a
"right-to-use" rather than a
 Joerg Hornstein
AC Immune SA
December 4, 2019
Page 2
              Explain how Lilly has used and is expected to use this license
during Phase 1 clinical
              trials and whether it has benefited from this license since the
effective date.
              Explain your consideration of factors discussed in IFRS 15.B58
and B59, particularly
              the extent to which Lilly has been or will be exposed to the
positive or negative
              results of your Phase 1 clinical trials.
              Provide support for your use of the residual approach to estimate
the standalone
              selling price for this license, given that this approach is only
permissible in limited
              Explain how the apparent premium implicit in the
              convertible note, which converted to common shares on April 23,
2019, impacted
              your determination of transaction price and revenue recognized in
              Refer us to the technical guidance upon which you relied.

       In closing, 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 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
December 4, 2019 Page 2                                        Office of Life
FirstName LastName