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May 22, 2020
Anthony Hayes
Chief Executive Officer
Aikido Pharma Inc.
One Rockefeller Plaza, 11th Floor
New York, NY 10020
Re:Aikido Pharma Inc.
Registration Statement on Form S-3
Filed May 11, 2020
File No. 333-238172
Dear Mr. Hayes:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 Statement on Form S-3
Prospectus Summary
Business Overview, page 1
1.We note several statements in this section regarding the efficacy of your product
candidates. Efficacy is a determination that is solely within the authority of the FDA or
similar foreign regulators. You may present clinical trial end points and objective data
resulting from trials without concluding efficacy, and you may state that your product
candidates are well tolerated if true. Please revise these statements accordingly.
Licenses, page 5
2.Please disclose the material terms of the Master License Agreement with the University of
Maryland, Baltimore and file it as an exhibit or explain to us why it is not material to an

 FirstName LastNameAnthony Hayes
 Comapany NameAikido Pharma Inc.
 May 22, 2020 Page 2
 FirstName LastName
Anthony Hayes
Aikido Pharma Inc.
May 22, 2020
Page 2
investment decision. Please also revise to indicate the current stage of development for the
licensed technology.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Ada D. Sarmento at 202-551-3798 or Celeste Murphy at 202-551-3257
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Robert F. Charron, Esq.