December 19, 2018 Neil Klompas Chief Financial Officer Zymeworks Inc. Suite 540 1385 West 8th Avenue Vancouver, British Columbia Canada V6H 3V9 Re: Zymeworks Inc. Registration Statement of Form S-3 Filed December 13, 2018 File No. 333-228782 Dear Mr. Klompas: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Sonia Bednarowski at 202-551-3666 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance