August 28, 2024

Andrew Saik
Chief Financial Officer and Treasurer
Arvinas, Inc.
5 Science Park
395 Winchester Ave
New Haven, Connecticut 06511

       Re: Arvinas, Inc.
           Form 10-K for the fiscal year ended December 31, 2023
           Filed February 27, 2024
           File No. 001-38672
Dear Andrew Saik:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for the fiscal year ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Financial Operations Overview
Research and Development Expenses, page 132

1.     We acknowledge your statement that you do not track all of our internal
research and
       development expenses on a program-by-program basis. In future filings,
please quantify
       your internal research and development costs separately from the
external costs incurred,
       and provide a further breakdown for each category. For example, you
could provide a
       breakdown of your internal costs by nature of the expense incurred, and
could disclose a
       breakdown of your external costs for each ongoing major clinical trial,
instead of, or in
       addition to a breakdown by program area. Explain to us and revise your
disclosures to
       clarify how the cost sharing arrangements with your collaboration
partners, such as Pfizer,
       are recorded and reported in your financial statements, or direct us to
existing disclosure.
 August 28, 2024
Page 2

Consolidated Financial Statements
Notes to Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition and Deferred Revenue, page F-10

2.     We note that you recognize revenues from several research collaboration
and license
       agreements, and that such revenues are recognized on either a
straight-line basis over the
       estimated performance period under the arrangement or over the estimated
performance
       period based on your best estimate of costs to be incurred. We also note
that your
       revenues could represent amounts from up front fees, option fees,
research funding fees,
       milestone payments, or royalties. Please explain to us your
consideration of
       providing disaggregated revenue disclosures into categories that enable
the users of your
       financial statements to better understand the nature, amount, timing,
and uncertainty of
       revenue and cash flows arising from your contracts with customers.
Please refer to the
       guidance in ASC 606-10-50-5 and ASC 606-10-55-89 through 91 in your
response.
       In closing, 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 Ibolya Ignat at 202-551-3636 or Daniel Gordon at
202-551-3486 with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences