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CORRESP
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    Wilson Sonsini Goodrich & Rosati

    Professional Corporation

    1881 9th Street

    Suite 110

    Boulder, CO 80302

    o: 303.256.5900

    f: 866.974.7329

July 9, 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.

Registration Statement on Form S-4

Filed June 18, 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 3, 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. 2 to the First Amended Registration Statement (the
“Second 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. 1 to Registration Statement
on Form S-4

Oruka’s Pipeline, page 214

 1. We note your response to prior comment 11 and your revised disclosure on page 214. We note that the
pipeline table does not provide an indication for ORKA-003 or “Combinations.” Given the status of development and limited disclosure
regarding the programs for ORKA-003 and “Combinations,” it does not appear appropriate to highlight these programs in your pipeline
table. If these programs are material to your business to warrant inclusion in your pipeline table, please expand your disclosure in your
Business section to provide a more fulsome discussion of these programs, including descriptions of preclinical studies or other development
activities conducted. Alternatively, please remove these programs from the pipeline table or advise.

Response:
The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the pipeline table on page 214
of the Second Amended Registration Statement to remove the programs from the pipeline table in response to the Staff’s comment.

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 9, 2024

Page 2

 2. Please revise your pipeline table to include columns of equal width for each of Phase 1,
Phase 2 and Phase 3 of clinical testing.

Response:
The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the pipeline table on page 214
of the Second Amended Registration Statement in response to the Staff’s comment.

*****

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