July 22, 2024

Steven Pieper
Chief Financial Officer
Xeris Biopharma Holdings, Inc.
1375 West Fulton Street, Suite 100
Chicago, IL 60607

       Re: Xeris Biopharma Holdings, Inc.
           Form 10-K for the year ended December 31, 2023
           Form 10-Q for the quarterly period ended March 31, 2024
           File No. 001-40880
Dear Steven Pieper:

       We have reviewed your June 21, 2024 response to our comment letter and
have the
following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our June
12, 2024 letter.

Form 10-Q for the quarterly period ended March 31, 2024
Management's Discussion Analysis of Financial Condition and Results of
Operations, page 21

1.     Your proposed disclosures in response to prior comment one say that
"Cost of goods sold
       as a percent of total revenue decreased by 3.0%, or 17.5% in 2023
compared to 20.5% in
       2022. This decrease was primarily due to collaboration agreements,
specifically upfront
       and milestone achievements resulting in revenue." However, cost of goods
sold as
       percent of product revenue for 2023 was 18.7% compared to 20.7% for
2022. Revise
       your proposed disclosure to explain the reasons for the decrease in cost
of goods sold as a
       percent of product revenue.

2.     Please address the following regarding your response to prior comment
two and your
       proposed related disclosures:
           You disclose on page 70 of your Form 10-K that the increase in
research and
           development expenses from 2022 to 2023 was driven by the expenses
related to the
 July 22, 2024
Page 2

           Phase 2 study for XP-8121. In your Form 10-Q for quarter ended March
31, 2024,
           you disclose that the increase in research and development expenses
was
           "driven by strategic investments in our pipeline, notably XP-8121,
and our emerging
           technology partnership business as well as higher personnel costs."
Please confirm
           which line item(s) in Appendix A includes the majority of the
expenses for XP-8121,
           and tell us the amount of the direct expenses related to XP-8121 for
2023 and the first
           quarter of 2024.
             Revise your proposed disclosures to clarify whether the line item
in Appendix A titled
           "Technology development" is the "emerging technology partnership
business" that
           you listed as a factor for the increase in research and development
expense on page 25
           of your Form 10-Q for the period ended March 31, 2024.
             As part of your future disclosures, revise to more clearly
disclose the extent to which
           your emerging technology partnership business has had revenues and
expenses in
           prior periods.
             Further clarify the extent to which any of the amounts reported as
Royalty, contract
           and other revenue related to this business. If so, quantify those
amounts and clarify
           the extent to which the expenses related to these amounts are
excluded from cost of
           goods sold but are included in research and development expenses.
             Revise your Business section in future filings to better identify
the activities of
           your technology partnership business and tie your discussions of
these partnerships to
           your results of operations.

       Please contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at
202-551-3494 if
you have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences