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 March 28, 2025

Mina Sooch
Nominating Shareholder
Opus Genetics, Inc.
6894 Lakemont Circle
West Bloomfield, MI 48323

 Re: Opus Genetics, Inc.
 PREC14A Filed March 21, 2025
 Filed by Mina Sooch et al.
 File No. 001-34079
Dear Mina Sooch:

 We have reviewed your filing and have the following comments.

 Please respond to these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

 After reviewing your response to these comments, we may have additional
comments.
All defined terms used herein have the same meaning as in your proxy statement.

PREC14A Filed March 21, 2025
General

1. On the preliminary proxy card and on pages 3 and 32, you indicate that
the proxy card
 will be voted based on the Restore Value Slate s recommendations if
the proxy card is
 properly executed and delivered, but does not specify voting
instructions. Please
 revise to clarify whether you are describing an entirely unmarked, but
signed proxy
 card, or one that is signed and marked as to other matters but not
marked as to the
 particular proposal addressed in your disclosure.
2. We note the following disclosure, which appears both on page 3 and page
37:
 "IMPORTANTLY, IF YOU MARK MORE THAN NINE (9) 'FOR' AND/OR
 'WITHHOLD' BOXES WITH RESPECT TO THE ELECTION OF DIRECTORS,
 ALL OF YOUR VOTES FOR THE ELECTION OF DIRECTORS WILL BE
 DEEMED INVALID." It is our understanding that only "FOR" votes are
relevant
 when it comes to the possibility of invalidation. Please revise
accordingly, or
 otherwise advise. In this regard, see the Company's disclosure on
"over-votes," which
 March 28, 2025
Page 2

 appears on page 9 of the Company's preliminary proxy statement, as well
as the
 related instruction on your own preliminary proxy card, which also
suggests that only
 "FOR" votes are relevant.
Background to Solicitation, page 6

3. We note your statement on page 16 that the Board has failed to
articulate the full
 commercial potential of the Viatris license agreement for Ryzumvi
despite industry
 valuations by analysts and similarly situated competitors with a
sole-focus on
 presbyopia, suggesting it could be worth hundreds of millions of
dollars. Please
 revise to provide further support for the valuations referenced here,
including the
 identities of the analysts and similarly situated competitors
mentioned.
4. We note your statement on page 17 that APX3330 is a promising
late-stage asset.
 Please revise to provide further support for this statement and to
reflect, if true, that
 APX3330 failed to meet its primary endpoint during its ZETA-1 Phase 2
clinical trial
 for diabetic retinopathy and that it has not been approved for Phase 3
clinical trials at
 this time.
Reasons for the Solicitation, page 10

5. We note the following statement on page 15: [T]he Board expanded the
C-suite from
 three to seven named executive officers, dramatically increasing
overhead without a
 clear corresponding benefit to stockholders. We also note the
reference to two
 additional Named Executive Officers (SVP of Corporate Development and
SVP of
 Finance) on page 19. Please revise to clarify that you are referring
to the Company s
 executive officers, as defined in Rule 3b-7, and not its named
executive officers,
 as defined in Item 402 of Regulation S-K, or otherwise advise.
Proposal One, page 24

6. Please revise this section to include Mr. Weber's present principal
occupation and a
 description of his business experience over the past five years. See
Items 5(b)(1)(ii)
 and 7(b) of Schedule 14A and Item 401(e)(1) of Regulation S-K.
Proposal Two, page 33

7. We note that disclosure in this section indicates that "WE MAKE NO
 RECOMMENDATION WITH RESPECT TO THIS PROPOSAL," whereas the proxy
 card indicates that the Restore Value Slate "RECOMMENDS YOU VOTE 'FOR'
 PROPOSAL 2." Please revise to clarify whether you are making a
recommendation
 on Proposal 2.
Votes Required for Approval, page 40

8. We note the disclosure in this section indicates that "[b]roker
discretionary voting is
 permitted" on Proposal 2. Please revise to clarify that broker
discretionary voting is
 not permitted if a stockholder receives proxy materials from the Restore
Value Slate
 and the Company.
 March 28, 2025
Page 3
Solicitation of Proxies, page 42

9. We note the following statement on page 42: Solicitations may be made
by certain of
 the respective directors, officers, members and employees of Ms. Sooch .
. . . Since
 Ms. Sooch is a natural person, please revise to clarify the potential
solicitors being
 referenced in this statement.
10. According to this section, the entire expense of soliciting proxies is
being borne by
 Ms. Sooch. However, the description of the Group Agreement on page 27
indicates
 that the Participants have agreed to share all expenses incurred in
connection with
 the Participant s activities. Please revise to clarify whether any
Participants other
 than Ms. Sooch are bearing the cost of the solicitation. See Item
4(b)(5) of Schedule
 14A.

 We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

 Please direct any questions to Shane Callaghan at 202-551-6977 or David
Plattner at
202-551-8094.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers &
Acquisitions
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