United States securities and exchange commission logo

                              January 7, 2021

       Jon Heimer
       Chief Executive Officer
       Knilo HoldCo AB
       Uppsala Science Park
       SE-751 83
       Uppsala, Sweden

                                                        Re: Knilo HoldCo AB
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted on
December 11, 2020
                                                            CIK No. 0001835539

       Dear Mr. Heimer:

              We have reviewed your draft registration statement 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 disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form F-1 submitted on December 11, 2020

       Risk Factors
       Because we have elected to take advantage of the    controlled company
 exemption..., page 50

   1.                                                   Please expand to
disclose the percentage of your voting power Summa Equity AB
                                                        currently beneficially
owns and is expected to beneficially own immediately following the
                                                        closing of the
offering. Additionally, disclose that you are a controlled company in the
                                                        Prospectus Summary.
       Use of Proceeds, page 63

   2.                                                   We note that you plan
to use a portion of the proceeds of this offering to repay your
 Jon Heimer
FirstName  LastNameJon Heimer
Knilo HoldCo  AB
January    NameKnilo HoldCo AB
        7, 2021
Page 2 7, 2021 Page 2
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         current outstanding credit facilities. Please expand to disclose the
amount outstanding
         under these facilities and the material terms of repayment. Please
also expand to disclose
         the amount outstanding under those facilities as of the latest
practicable date and describe
         the interest rate and maturity of such indebtedness and, for
indebtedness incurred within
         the past year, the uses to which the proceeds of such indebtedness
were put. Please refer
         to Item 3.C.4 of Part I of Form 20-F.
Management's Discussion and Analysis of Financial Condition and Results of
Key Indicators of Performance and Financial Condition, page 75

3.       We note that you eliminate management adjustments when calculating
non-IFRS Adjusted
         EBITDA and that you believe that these costs are not reflective of
your normal course of
         business. We further note that these costs consist of impairment of
intangible assets;
         system and process improvements, integration and reorganization costs;
and recognition
         of the step up in inventory. Please revise to quantify and describe
the nature of these costs
         and explain why these costs are not normal recurring expenses
necessary to operate your
         business. Refer to Question 100.01 of the Compliance and Disclosure
Interpretations on
         Non-GAAP Financial Measures.
4.       Further, we note that several of these management reconciling items
appear to be
         recurring in nature since you reported similar costs in the comparable
periods. Please tell
         us how you considered the guidance in Item 10(e) of Regulation S-K
which prohibits
         adjusting a non-GAAP financial performance measure to eliminate or
smooth items
         identified as unusual when the nature of the charge or gain is such
that it is reasonably
         likely to recur within two years or there was a similar charge or gain
within the prior two
         years. Otherwise, revise your presentation to comply.
Overview, page 91

5.       We note your disclosure here and elsewhere that your customers
carefully and rigorously
         vet and validate your technology before adopting Olink. Please expand
your disclosure to
         describe the process whereby customers vet your technology.
6.       We note your disclosure in the last paragraph on page 93 and on page 3
that you plan to
         increase your library to approximately 3,000 protein biomarker targets
in 2021 and to over
         6,000 protein biomarker targets over time. Please expand your
disclosure to describe how
         you plan to accomplish this in greater detail. We also understand from
your disclosure
         that your detection technology relies on a matched pair of two
antibodies each with a
         complementary DNA tag that hybridizes when in close proximity. Please
clarify whether
         expanding your biomarker targets beyond your current library could be
limited if some
         proteins require more than two antibodies for identification.
7.       We note your disclosure that you anticipate that the first diagnostic
protein signature
         based on PEA will be commercialized by one of our customers in the
diagnostics market
 Jon Heimer
Knilo HoldCo AB
January 7, 2021
Page 3
         in 2021. Please clarify how you plan to derive revenue from such
Our Market Opportunity, page 112

8.       We note that you estimate your addressable market is $35 billion,
which consists of a $19
         billion research opportunity and a $16 billion clinical opportunity.
Please expand your
         disclosure to describe how you developed this estimate.
Intellectual Property, page 124

9.       Please expand your disclosure to discuss the durations of the patents
you own or in-
Related Party Transactions
Management Services Agreement, page 137

10.      Please disclose if payments will be made to Summa Equity AB under the
         Services Agreement after the consummation of your offering and how any
such payments
         would be determined. Please also file this agreement as an exhibit to
your registration
         statement of tell us why such agreement is not required to be filed.
Principal Shareholders, page 139

11.      Please ensure that you identify the natural persons who are the
beneficial owners of the
         shares held by the 5% or greater shareholder identified in your table.
Description of Share Capital and Articles of Association, page 140

12.      We note from your introduction to this section that your summary of
your share capital
         stock is qualified by reference to "applicable Swedish law." You may
not qualify
         disclosure by reference to information outside the registration
statement. Please revise as
13.    We note your disclosure on page 55 that your articles of association
will provide that the
       United States District Court for the District of Delaware shall be the
sole and exclusive
       forum for resolving any complaint filed in the United States asserting a
cause of action
       arising under the Securities Act. Please expand your disclosure in this
section to clearly
       describe your federal forum provision, address any uncertainty as to its
enforceability and
FirstName LastNameJon Heimer
       discuss the impact it may have on investors, including increased costs
to bring a claim and
Comapany    NameKnilo
       that the         HoldCo
                provisions       AB
                           can discourage  claims or limit investors    ability
to bring a claim in a
         7, 2021forum
                 Page that
                       3 they find favorable.
FirstName LastName
 Jon Heimer
FirstName  LastNameJon Heimer
Knilo HoldCo  AB
January    NameKnilo HoldCo AB
        7, 2021
Page 4 7, 2021 Page 4
FirstName LastName

14.      Please provide us with copies of all written communications, as
defined in Rule 405 under
         the Securities Act, that you, or anyone authorized to do so on your
behalf, present to
         potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they
         retain copies of the communications.
        You may contact Tara Harkins at (202) 551-3639 or Terence O   Brien at
(202) 551-3355
if you have questions regarding comments on the financial statements and
related matters.
 Please contact David Gessert at (202) 551-2326 or Tim Buchmiller at (202)
551-3635 with any
other questions.


                                                              Division of
Corporation Finance
                                                              Office of Life
cc:      Kristopher D. Brown, Esq.