February 4, 2019

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 December 18, 2018
           CIK 0001757097

Dear Prof. Arndt Rolfs:

      We have reviewed your amended draft registration statement and have the
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

Amendment No.1 to Draft Registration Statement on Form F-1

Revenue, page 84

1.     For your diagnostic segment please disclose the extent to which your
change in revenue
       was impacted by changes in price. Refer to Item 5.A.1 of Form 20-F.
 Prof. Arndt Rolfs, MD
Centogene B.V.
February 4, 2019
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Results of Operations
Nine Months Ended September 30, 2017 Compared to Nine Months Ended September
30, 2018
Cost of Sales, page 86

2.    Please tell us why you believe the 26.3% increase in cost of sales was
largely in line with
      the increase in test orders received when your test orders received
increased by 66.7% per
      your disclosure on page 85.
Principal Shareholders, page 147

3.    Please clarify that the table also discloses the amount of shares to be
issued following the
      exchange of Centogene AG equity interests into shares of Centogene B.V.
4.    Please identify in footnotes to the table all natural persons who have
voting and
      investment power over the shares over the shares held by DPE and TVM Life
      Ventures VII L.P.

5.    Please revise the legal opinion filed as exhibit 5.1 to delete
assumptions that are overly
      broad and are readily ascertainable facts, such as that the company has
not been
      dissolved. For guidance, see Staff Legal Bulletin No. 19 (CF), Section
II.B.3.a, which is
      available on our website.
       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
Pamela Howell at 202-551-3357 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.
February 4, 2019 Page 2
cc:       Leo Borchardt
FirstName LastName