November 27, 2018

Prof. Arndt Rolfs, MD
Chief Executive Officer
Centogene B.V.
Am Strande 7
18055 Rostock

       Re: Centogene B.V.
           Draft Registration Statement on Form F-1
           Submitted October 31, 2018
           CIK 0001757097

Dear Prof. Arndt Rolfs:

       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
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

Draft Registration Statement on Form F-1 Submitted October 31, 2018


1.     Please supplementally 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.
2.     You state on page 35 of the draft registration statement that you have
contracts with
       several laboratories in Iran through which you provide diagnostic tests
You do not
       quantify this activity. You state on pages 28 and 29 of the draft
registration statement that
       you derived 27.9% of your 2017 revenues from the Middle East, and you
state on pages
 Prof. Arndt Rolfs, MD
FirstName LastNameProf. Arndt Rolfs, MD
Centogene B.V.
Comapany 27, 2018
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         80 and 117 that major markets for your diagnostics business include
the "Middle East and
         North Africa region." North Africa and the Middle East include Sudan
and Syria.

         Iran, Sudan and Syria are designated by the U.S. Department of State
as state sponsors of
         terrorism, and are subject to U.S. economic sanctions and/or export
controls. Please
         describe to us the nature and extent of your past, current, and
anticipated contacts with
         Iran, Sudan and Syria, including contacts with their governments,
whether through
         subsidiaries, affiliates, distributors, partners, customers, joint
ventures or other direct or
         indirect arrangements. Please also discuss the materiality of those
contacts, in quantitative
         terms and in terms of qualitative factors that a reasonable investor
would deem important
         in making an investment decision. Tell us the approximate dollar
amounts of revenues,
         assets and liabilities associated with those countries for the last
two fiscal years and the
         subsequent interim period. Address for us the potential impact of the
investor sentiment
         evidenced by divestment and similar initiatives that have been
directed toward companies
         that have operations associated with U.S.-designated state sponsors of
Management's Discussion and Analysis of Financial Condition and Results of
Financial Operations Overview
Pharmaceutical, page 79

3.       You state that you can experience different revenue patterns
quarter-to-quarter and year-
         over-year due to the significant upfront payments or investments made
by our
         pharmaceutical partners. Please tell us how you are accounting for
these upfront
Results of Operations
Year Ended December 31, 2016 Compared to Year Ended December 31, 2017, page 82

4.       Your disclosure under Note 7, Segment Information, indicates that you
         performance based on Adjusted EBITDA for each segment. Please expand
         discussion of the results of operations for each of your reportable
segments to describe the
         underlying drivers for the changes in segment Adjusted EBITDA between
         periods. If there are multiple drivers that are responsible for the
changes, please discuss
         and quantify the effect of each driver that you have identified.
Please refer to Item 4 of
         Form F-1 and Item 5 of Form 20-F for guidance.
Contractual Obligations and Commitments, page 87

5.       We note your disclosure in the risk factors section that you received
waivers for the
         breach of equity and net debt ratio covenants under the Syndicated
Loan Facility and that
         you are in the process of obtaining a further waiver from, or
amendment of, the financial
         covenant terms of the facility for the year ended December 31, 2019.
Please disclose the
         steps that the company intends to take to cure, obtain waivers of or
otherwise address any
 Prof. Arndt Rolfs, MD
FirstName LastNameProf. Arndt Rolfs, MD
Centogene B.V.
Comapany 27, 2018
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         expected breach in 2019. For guidance, refer to Section IV.C of SEC
Release 33-8350
         (December 29, 2003).
Certain Relationships and Related Party Transactions, page 141

6.       We note your disclosure on page F-39 that remuneration of EUR 476k
(2016: EUR
         1,242k) was provided to an entity controlled by key management
personnel in respect of
         IT and consulting services. Please provide the disclosure required by
Item 4 of Form F-1
         and Item 7.B of Form 20-F or advise.
Description of Share Capital and Articles of Association, page 142

7.       Please include discussion of how management may make calls on
shareholders for
         amounts owed. See Item 10.B.3(g) of Form 20-F.
Information Reporting and Backup Withholding, page 178

8.       If applicable and material, please include discussion of the foreign
financial assets
         requirements under the Hiring Incentives to Restore Employment Act of
Consolidated Statements of Comprehensive Loss for the Years Ended December 31,
2016 and
2017, page F-3

9.       Please revise your financial statements to separately present loss for
the year attributable
         to equity holders of the parent and non-controlling interests as
required by paragraph
         81B(a) of IAS 1.
5 Accounting and Measurement Principles
Revenue, page F-9

10.      We note that you recognize revenue from clinical diagnostic services
based on the
         percentage of completion method. Please expand your accounting policy
disclosure to
         describe the terms of the transactions and explain to us how these
transactions meet the
         conditions in paragraph 20 of IAS 18. Please also disclose how you
assess the percentage
         of completion of the service on the reporting date based on the work
rendered. Refer to
         paragraph 35 of IAS 18.
11.      Please expand your disclosure to describe the terms of fixed fee
partnership agreements
         under your pharmaceutical segment and explain to us how you have
         recognizing revenue with a fixed service fee on the pro rata basis
over the contract period
         is consistent with IAS 18.
Notes to the Consolidated Financial Statements, Centogene AG
19 Share-Based Payments, page F-31

12.      Please reconcile the total expenses arising from share-based payment
transactions for
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Centogene B.V.
November 27, 2018
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       2017 disclosed on page F-33 to the share-based payments amount presented
in your
       consolidated statement of changes in equity for the year ended December
31, 2017.
Undertakings, page II-4

13.    Please provide the undertaking required by Item 512(a)(6) of Regulation
S-K. Item
       512(a)(6) is required for any offering that involves an initial
distribution of securities
       pursuant to Rule 159A.
Exhibit Index, page II-6

14.    Please file your lease agreement for your Cambridge, Massachusetts
facility described on
       page 130 or advise. Refer to Item 8 of Form F-1.
       You may contact Suying Li at 202-551-3335 or Joel Parker at 202-551-3651
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jonathan Burr at 202-551-5833 or Brigitte Lippmann at 202-551-3713 with any
other questions.


FirstName LastNameProf. Arndt Rolfs, MD                        Division of
Corporation Finance
                                                               Office of
Beverages, Apparel and
Comapany NameCentogene B.V.
November 27, 2018 Page 4
cc:       Leo Borchardt
FirstName LastName