November 22,
2019

Douglas Love, Esq.
President and Chief Executive Officer
Annexon, Inc.
180 Kimball Way, Suite 200
South San Francisco, CA 94080

       Re: Annexon, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted November 8, 2019
           CIK No. 0001528115

Dear Mr. Love:

      We have reviewed your amended 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 response.

      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
comments.

Amendment No. 1 to Draft Registration Statement on Form S-1 submitted November
8, 2019

Prospectus Summary
Our Pipeline, page 3

1.     We note that you have revised the Status column of your pipeline chart
to remove the
       timing of initiation of future clinical trials. Please reinsert this
information to provide
       context to the status of the pipeline or advise.
2.     We note your disclosure that you intend to advance ANX009 through IND
enabling
       studies, select your initial lead autoimmune disease indication and
commence a FIH
       clinical trial in healthy volunteers in 2020. Your pipeline chart
suggests that you have
       completed preclinical testing of ANX009. Please shorten the arrow for
ANX009 as
       appropriate to illustrate how far along you are in preclinical testing.
 Douglas Love, Esq.
Annexon, Inc.
November 22, 2019
Page 2
Business
Phase 1b Trial in GBS Patients, page 102

3.    We note your disclosure that the Phase 1b trial was not statistically
powered for
      significance on the efficacy measures and that your results are promising
but not
      statistically significant. We also note your disclosure on page 101 that
a p-value lower
      than 0.05 is considered statistically significant. Given these
statements, please explain
      why it is appropriate to disclose the p-values for your Phase 1b efficacy
data.
        You may contact Mary Mast at (202) 551-3613 or Angela Connell,
Accounting Branch
Chief, at (202) 551-3426 if you have questions regarding comments on the
financial statements
and related matters. Please contact Irene Paik at (202) 551-6553 or Joseph
McCann at (202) 551-
6262 with any other questions.



                                                            Sincerely,
FirstName LastNameDouglas Love, Esq.
                                                            Division of
Corporation Finance
Comapany NameAnnexon, Inc.
                                                            Office of Life
Sciences
November 22, 2019 Page 2
cc:       Brian J. Cuneo - Latham & Watkins LLP
FirstName LastName