SecProbe.io

Mail Stop 6010           October 25, 2007  Peter M. Strumph Chief Executive Officer Nile Therapeutics, Inc.  2850 Telegraph Avenue, Suite 310 Berkeley, CA  94705
Re: Nile Therapeutics, Inc.
 Registration Statement on Form SB-2  File Number 333-146843

Dear Mr. Strumph:
This is to advise you that we have lim ited our review of the above referenced
registration statement to only the issues identified below.  We will make no further review of this filing.

Form SB-2

Selling Shareholder, page 40

1. We note the disclosure you include in the risk factor entitled “There are certain
interlocking relationships betw een us and certain . . . .” on page 16. You indicate that
one of your directors, Peter M. Kash, is al so a director of a br oker-dealer. In that
regard, please revise your Selling Shareholder table to disclose the following, if true:

• that he purchased in the ordi nary course of business; and
• that at the time of the purchase, he  had no agreements or understanding to
distribute the securities.

To the extent any of your other selling share holders are also affiliates of broker dealer,
please ensure you provide similar repres entations for each of those selling
shareholders.
 Signature Page

2. Your principal financial officer and  either a controller or chief accounting officer must
sign the registration statement. Your next amendment and all subsequent amendments

 2must contain this signature. If a person acts in more than one of these capacities, the
signature page must indicate all of the capacities in wh ich they are signing. Please
revise your signature page accordingly.

Audit Report
3. Reference is made to your audit report on page F-1 that states that your auditors
conducted their audit “in accordance with a uditing standards generally accepted in the
United States of America.”  According to  PCAOB Auditing Standards No. 1, it should
instead refer to “the standards of the Public Company Accounting Oversight Board
(United States).”  Please revise accordingly.

* * *
 Once you have cleared our comments, we w ill act upon any request for acceleration of
the effective date of the Form SB-2 and pursuant to delegated authority, grant acceleration of
the effective date.  We will consider your request  for acceleration as a confirmation of the fact
that you are aware of your res ponsibilities under th e Securities Act of 1933 and the Securities
Act of 1934 as they relate to  the proposed public offering.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the sta ff to be certain that they have provided all
information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.

 Notwithstanding our comments, in the even t the company requests acceleration of the
effective date of the pending registration statemen t, it should furnish a letter, at the time of
such request, acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

 3In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
Please contact Song P. Brandon at (202) 551- 3621 or me at (202) 551-3710 with any
other questions.
Sincerely,

Jeffrey Riedler Assistant Director
  cc: Ira L. Kotel, Esq.  Dickstein Shapiro, LLP  1177 Avenue of the Stars  New York, NY  10036