SecProbe.io

CORRESP
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    Wilson
Sonsini Goodrich & Rosati

Professional Corporation

    1881
    9th Street

    Boulder,
Colorado 80302-5148

    o:
    303.256.5900

    f: 866.974.7329

    July 22, 2024

Via
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
D.C. 20549-3628

Attention:
Ibolya Ignat, Daniel Gordon, Tamika Sheppard and Joshua Gorsky

 Re: ARCA
biopharma, Inc.

Amendment
No. 2 Registration Statement on Form S-4

Filed
July 9, 2024

File
No. 333-279387

Ladies
and Gentlemen,

On
behalf of ARCA biopharma, Inc. (the “Company”), we are submitting this letter to the Securities and Exchange Commission
(the “SEC”) via EDGAR in response to the comment letter from the staff of the SEC (the “Staff”),
dated July 16, 2024 (the “Comment Letter”), pertaining to the Company’s above-referenced Registration Statement
on Form S-4/A (the “First Amended Registration Statement”). In connection with such responses, the Company is concurrently
filing Amendment No. 3 to the Second Amended Registration Statement (the “Third Amended Registration Statement”).

For
your convenience, the Staff’s comments are summarized in this letter, and each comment is followed by the applicable responses
on behalf of the Company. Unless otherwise indicated, page references in the responses correspond to the page numbers in the Second Amended
Registration Statement. Capitalized terms used in this letter but otherwise not defined herein shall have the meanings set forth in the
Second Amended Registration Statement.

Amendment
No. 2 to Registration Statement on Form S-4

Opinion
of Lucid, ARCA’s Financial Advisor, to ARCA’s Board of Director, page 112

 1. We
                                            note your disclosure that Lucid, in connection with its opinion, "[r]eviewed and analyzed
                                            certain internal financial analyses, including . . . projections as to cost and expenses
                                            . . . and other information concerning Oruka prepared by Oruka[.]" Please disclose these
                                            financial projections and discuss the material assumptions and limitations underlying the
                                            financial projections or, alternatively, please explain why such disclosures are not required
                                            pursuant to Item 4(b) of Form S-4 and Item 1015(b)(6) of Regulation MA.

Response:
The Company respectfully acknowledges the Staff’s comment and advises the Staff that the requested disclosure was previously included
on pages 113 and 264 of the Third Amended Registration Statement. The Company respectfully directs the staff to the language set forth
on pages 113 and 264, which is as follows:

Further,
as ARCA’s board of directors was aware, Oruka’s management did not provide Lucid with, and Lucid did not otherwise have access
to, financial forecasts regarding Oruka’s businesses, other than certain cash burn projections, and, accordingly, Lucid did not
perform either a discounted cash flow analysis or any multiples-based analyses with respect to Oruka.

austin
     beijing
     boston
     BOULDER
     brussels
     hong kong
     london
      los angeles
     new york
     palo alto
     SALT LAKE CITY
     san diego
     san francisco
      seattle
     shanghai
     washington, dc
     wilmington, de

Securities
and Exchange Commission

July
22, 2024

Page
2

In
response to the Staff’s comment, the Company has revised the above disclosure on page 113 of the Third Amended Registration Statement
to clarify that the expected net proceeds from the Merger and the Oruka pre-closing financing, together with Oruka’s existing cash
and sales of additional convertible notes under the Purchase Agreement, will enable Oruka to fund its operating expenses through 2027.

*****

Please
contact the undersigned at (303) 256-5901 or via email at bfassett@wsgr.com if you have any questions with respect to the foregoing.

  Very truly yours,

  /s/ Brent D. Fassett

  Brent D. Fassett

  Wilson Sonsini Goodrich & Rosati P.C.

cc: Thomas
                                            A Keuer, ARCA biopharma, Inc.

C.
Jeffrey Dekker, ARCA biopharma, Inc.

Ethan
Lutske, Wilson Sonsini Goodrich & Rosati P.C.

Ross
Tanaka, Wilson Sonsini Goodrich & Rosati P.C.

Savir
S. Punia, Wilson Sonsini Goodrich & Rosati P.C.

Ryan
A. Murr, Gibson, Dunn & Crutcher LLP

Branden
C. Berns, Gibson, Dunn & Crutcher LLP