Exhibit 19.1

InSIDER TRADING PREVENTION Policy

It is the policy of Invivyd, Inc. and its subsidiaries (“Invivyd”) to prohibit insider trading, i.e., the purchase or sale of a company’s securities by anyone who is aware of Material Non-Public Information (as defined below) about that company. Taking advantage of this privileged information is considered a breach of the individual’s fiduciary duty to Invivyd, and accordingly Invivyd adopts this Insider Trading Prevention Policy (this “Policy”) to provide guidance to Invivyd employees, officers, directors, and contractors and consultants who are advised that they are subject to this policy (“Invivyd Representatives”) regarding transactions in both Invivyd securities and the securities of publicly traded companies with whom Invivyd has a business relationship. Federal and state securities laws prohibit the purchase or sale of a company’s securities by anyone who is aware of Material Non-Public Information about that company. These laws also prohibit anyone who is aware of Material Non-Public Information from disclosing this information to others who may trade. Companies may also be subject to liability if they fail to take reasonable steps to prevent insider trading by their personnel.

This Policy is designed to prevent insider trading by Invivyd Representatives or even the allegations of insider trading, and to assist Invivyd Representatives in complying with their obligations under federal and state securities laws. Your strict adherence to this Policy can help safeguard Invivyd’s reputation and further ensure that Invivyd conducts its business with the highest level of integrity and in accordance with the highest ethical standards. Each Invivyd Representative is responsible for the consequences of his or her actions, and for understanding and complying with this Policy. Any violation of this Policy can result in disciplinary action up to and including termination of employment or other working relationship with Invivyd.

This Policy applies to all Invivyd Representatives and to their Family Members (defined as members of their immediate families who reside with them or anyone else who lives in their household or who live elsewhere but whose transactions in Invivyd securities are directed by such Invivyd Representatives or subject to their influence and/or control (including, e.g., parents or children who consult with you before they trade in Invivyd securities)) and controlled entities (defined as any corporation, limited liability company, partnership, trust, or any venture or other investment fund, if you influence, direct or control transactions by such entity). However, this Policy does not apply to any entity that invests in securities in the ordinary course of its business (e.g., a venture or other investment fund) if (and only if) such entity has certified to Invivyd that it has established its own insider trading controls and procedures in compliance with applicable securities laws (an “Excluded Entity”), and this Policy shall not prohibit disclosure by a director to an Excluded Entity of information learned during the course of his or her service as a director.

This Policy also applies to all transactions in Invivyd securities, including common stock, restricted stock, restricted stock units, options and warrants to purchase common stock and any other debt or equity securities Invivyd may issue from time to time, such as bonds, preferred stock and convertible debentures, as well as to derivative securities relating to Invivyd’s securities, whether or not issued by Invivyd, such as exchange-traded options.

“Material Non-Public Information” is any material information about Invivyd that has not been previously disclosed to the general public through a press release or securities filings and is otherwise not available to the general public. Information may still be non-public even though it is widely known within Invivyd. Information can be deemed “material” if a reasonable investor would likely consider it important in making a decision to buy, hold or sell securities. Any information that could reasonably be expected to affect the price of the security is material. The information may be positive or negative. Financial information is frequently material, even if it covers only part of a fiscal period or less than all of Invivyd’s operations, since either of these might convey enough information about Invivyd’s results to be considered material information. Please note that trading that becomes subject to government or other scrutiny will be evaluated after the fact of the trade with the benefit of hindsight, so if you are unsure whether any particular information is Material Non-Public Information, you should first consult with the Invivyd Legal Department or alternatively resolve the question in favor of deeming the information material and therefore avoid the trade.

It is not possible to list or define all categories of material information. However, there are various categories of information that are particularly sensitive and, as a general rule, should always be considered material. Examples of such information may include:

Material Non-Public Information about Invivyd is confidential and is the property of Invivyd, and unauthorized disclosure or use of that information is prohibited.

No Invivyd Representative shall engage in any transaction involving a purchase or sale of Invivyd’s securities, including any offer to purchase or offer to sell, during any period commencing on the date that he or she comes into possession of Material Non-Public Information concerning Invivyd and ending at the close of business on the second trading day (as defined below) following the date of public disclosure of that information, or at such time as such Material Non-Public Information is no longer material. For purposes of this Policy, the term “trading day” shall mean a day on which national stock exchanges are open for trading.

Invivyd may engage in business transactions with companies whose securities are publicly traded. Information learned in connection with these transactions or relationships may constitute Material Non-Public Information about the other company. You are prohibited from trading in the securities of these companies while aware of Material Non-Public Information about the companies and from communicating that information to any other person for such use.

Any Invivyd Representative who engages in insider trading may be subject to penalties and sanctions, including:

Tipping is the disclosing or passing on of Material Non-Public Information about Invivyd or any other publicly traded company on to others, including Family Members or friends, or otherwise making unauthorized disclosure or use of this information, regardless of whether you profit or intend to profit by the tipping, disclosure, or use. Tipping is a violation of securities laws and can result in the same civil and criminal penalties that apply to insider trading, even though you as the tipper did not trade and did not gain any benefit from another's trading.

Any Invivyd Representative who tips is called a “tipper” and the third party who receives the tip is called a “tippee.” Tippers may be liable for improper transactions by tippees to whom they have tipped Material Non-Public Information regarding Invivyd or any other publicly traded company, or to whom they have made recommendations or expressed opinions on the basis of such information as to trading in Invivyd securities or the securities of another publicly traded company. Tippers and tippees may be subject to the same penalties set forth in Section V even if the tipper or tippee did not profit from the trading.

In an effort to ensure compliance with this Policy and applicable federal securities laws, and to avoid even the appearance of trading on the basis of Material Non-Public Information, Invivyd requires that all Invivyd officers, directors and employees and their Family Members, and others as may be identified by Invivyd’s Chief Financial Officer and/or Chief Legal Officer (collectively, “Restricted Persons”), are to be subject to periodic blocks of time called “Blackout Periods” during which they must refrain from conducting transactions involving the purchase or sale of Invivyd’s securities. No Restricted Person may trade in Invivyd securities during a specified Blackout Period, regardless of whether they are then actually aware of Material Non-Public Information.

Invivyd has established quarterly Blackout Periods, which, unless otherwise communicated by the Approving Person (as defined below), will begin upon completion of the trading day (if applicable) on the final day of each fiscal quarter and end after two full trading days have elapsed since the public dissemination of Invivyd’s financial results for such quarter, during which Restricted Persons must refrain from conducting transactions involving the purchase or sale of Invivyd’s securities. The quarterly Blackout Period may commence early, late, or may be extended upon a determination by the Chief Financial Officer and the Chief Legal Officer that such Blackout Period would be appropriate based on the facts and circumstances, including the existence of undisclosed information that would make trades by Restricted Persons inappropriate. It is important to note that the fact that the quarterly Blackout Period has commenced early or has been extended should be considered Material Non-Public Information that should not be communicated to any other person. Any exceptions to the quarterly Blackout Period must be approved by an Approving Person.

From time to time, an event (a “Special Event”) may occur that is material to Invivyd and is known by only a few directors, officers and/or employees (collectively, “Designated Restricted Persons”). So long as the Special Event remains material and non-public, Designated Restricted Persons must refrain from conducting transactions involving the purchase or sale of Invivyd’s securities. In that situation, the Approving Person will notify the Designated Restricted Persons that they may not trade in Invivyd’s securities. The existence of a Special Event Blackout Period should also be considered Material Non-Public Information and should not be communicated to any other person, including any other Designated Restricted Person. Even if you have not been identified as a Designated Restricted Person who should not trade due to a Special Event

Blackout Period, you should not trade while aware of Material Non-Public Information. Exceptions will not be granted during a Special Event Blackout Period.

The foregoing does not apply to the following transactions:

Bona fide gifts of securities of Invivyd (including transfers of securities of Invivyd made to trusts for estate planning purposes, as well as charitable contributions) are not transactions restricted by this Policy, unless the person making the gift has reason to believe that the recipient intends to sell such securities while the person making the gift is aware of Material Non-Public Information, or unless the person making the gift is a Restricted Person and a sale of such securities by the recipient is likely to occur during a Blackout Period, provided that all gift transactions are subject to the pre-clearance requirements specified in Section 9.0 below.

All Invivyd officers, directors and employees and others as may be identified by Invivyd’s Chief Financial Officer and/or Chief Legal Officer (a “Pre-Clearance Designee”) must obtain

pre-clearance by the Chief Financial Officer and/or Invivyd’s Chief Legal Officer (each an “Approving Person”) before engaging in any transaction involving Invivyd securities, including, but not limited to, purchases, sales, and gifts. Pre-Clearance Designees will be notified from time to time by the Chief Financial Officer and/or the Chief Legal Officer of the applicable pre-clearance or other procedures applicable to them. Neither Approving Person may engage in a transaction in Invivyd securities unless the other Approving Person has pre-cleared the transaction.

The Approving Persons are under no obligation to approve a transaction submitted for pre-clearance and may determine not to permit a transaction, even if it would not violate the federal securities laws or a specific provision of this Policy. If a request for pre-clearance is approved, the Pre-Clearance Designee has two business days from the date of approval to effect the transaction (or, if sooner, before commencement of a Blackout Period). Under no circumstance may a Pre-Clearance Designee engage in any transaction involving Invivyd securities while aware of Material Non-Public Information, even if pre-cleared. Thus, if a Pre-Clearance Designee becomes aware of Material Non-Public Information after receiving pre-clearance, but before the trade has been executed, the Pre-Clearance Designee must not proceed with the pre-cleared transaction.

Pre-clearance of any particular transaction does not insulate any Pre-Clearance Designee from liability under the securities laws. The ultimate responsibility for determining whether an individual is aware of Material Non-Public Information about Invivyd rests with that individual in all cases.

Regardless of the other provisions under this Policy, including whether pre-clearance is obtained, all Pre-Clearance Designees must promptly report any purchases or sales or gifts of Invivyd’s securities to the Chief Legal Officer to permit timely preparation of any necessary filings with the Securities and Exchange Commission.

This section sets forth guidelines for any trading plan (a “10b5-1 trading plan”) adopted under Rule 10b5-1 (“Rule 10b5-1”) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), covering publicly traded stock of Invivyd. In addition to honoring these guidelines, all 10b5-1 trading plans, along with any amendments or modifications to those plans, must comply with Rule 10b5-1.

This Policy continues to apply to transactions in Invivyd securities even after an Invivyd Representative resigns or otherwise separates from Invivyd. If an Invivyd Representative who resigns or separates from Invivyd is in possession of Material Non-Public Information at that time, he or she may not trade in Invivyd securities until that information has become public or is no longer material.

Invivyd is subject to the SEC’s Regulation FD and must avoid selective disclosure of Material Non-Public Information. Invivyd will release such information in a manner that is designed to achieve broad public dissemination of that information immediately upon its release. Accordingly, only the Invivyd executive officers who have been authorized to engage in communications with the public may disclose information to the public regarding Invivyd, its business activities and financial affairs. The public includes, without limitation, research analysts, portfolio managers, financial and business reporters, news media and investors. Because of the risks associated with the exchange of information through such communications media, Invivyd Representatives are strictly prohibited from posting or responding to messages containing information regarding Invivyd on Internet “social media,” Internet “bulletin boards,” Internet “chat rooms” or in similar online forums. Invivyd Representatives who inadvertently disclose any Material Non-Public Information must immediately advise the Chief Legal Officer so that Invivyd can assess its obligations under Regulation FD and other applicable securities laws. Please review Invivyd’s Corporate Disclosure Policy for additional information.