United States securities and exchange commission logo





                             January 15, 2021

       Alexandre Teixeira de Assump    o Saigh
       Chief Executive Officer
       Patria Investments Limited
       18 Forum Lane, 3rd floor,
       Camana Bay, PO Box 757, KY1-9006
       Grand Cayman, Cayman Islands

                                                        Re: Patria Investments
Limited
                                                            Amendment No. 2 to
                                                            Registration
Statement on Form F-1
                                                            Filed January 14,
2021
                                                            File No 333-251823

       Dear Mr. Saigh:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration on Form F-1 - Amendment No. 2

       Dilution, page 95

   1.                                                   Please update your
dilution metrics to include the impact of the $25 million in dividends
                                                        paid to your
shareholders on December 2020. Refer to Item 506 of Regulation S-K.
 Alexandre Teixeira de Assump    o Saigh
Patria Investments Limited
January 15, 2021
Page 2


       You may contact Michelle Miller at 202-551-3368 or David Irving at
202-551-3321 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Julia Griffith at 202-551-3267 or Susan Block at 202-551-3210 with any
other questions.



                                                     Sincerely,
FirstName LastNameAlexandre Teixeira de Assump    o Saigh
Comapany NamePatria Investments Limited
                                                     Division of Corporation
Finance
January 15, 2021 Page 2                              Office of Finance
FirstName LastName