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 July 30, 2025

James Martin
Co-Chief Executive Officer and CFO
Cocrystal Pharma, Inc.
19805 North Creek Parkway
Bothell, WA 98011

 Re: Cocrystal Pharma, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-K filed March 31, 2025
 File No. 001-38418
Dear James Martin:

 We have reviewed your filing and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2024
Item 1. Business, page 3

1. We note several statements throughout your filing that describe your
product
 candidates as "first-in-class" and "best-in-class." Given the early
stage of development
 of your product candidates and the length and uncertainty of the drug
approval
 process, it appears premature to describe your product candidates as
potentially being
 "first-in-class" or "best-in-class." Accordingly, please remove these
statements from
 future filings.
Research and Development Update, page 5

2. We note the inclusion of "Replication Inhibitors" and "Pan-viral
Inhibitors" in your
 pipeline table. Given the early stage of development and limited
disclosure related to
 these programs, please explain why they are sufficiently material to
your business to
 warrant inclusion in your pipeline table. If they are material, please
expand your
 disclosure in the "Business" section in future filings to provide a more
fulsome
 discussion of these programs, including a description of development
activities
 July 30, 2025
Page 2

 conducted. Alternatively, remove any programs that are not currently
material from
 your pipeline table in future filings.
3. In future filings, please revise your pipeline table to ensure the arrow
in each row
 accurately reflects the current status of the respective program
consistent with your
 disclosure in the rest of the filing. For example only, we note the
following:
 The arrow in the first row indicates that your Oral Pb2 Inhibitor
CC-42344
 program is nearing the end of Phase 2 clinical trials. However, your
disclosure on
 page 5 indicates that the program is still in Phase 2a clinical
trials and that you are
 considering the submission of a protocol amendment for the study.
 The arrow in the second row indicates that your Inhaled PB2
Inhibitor CC-42344
 program is at the end of preclinical studies. However, your
disclosure on page 39
 that "[p]reclinical development is progressing" suggests that you
are still in the
 preclinical phase.
Intellectual Property, page 8

4. In future filings, please revise your discussion of your patent
portfolio to disclose for
 each material patent and patent application the specific product(s) to
which such
 patents or applications relate, the type of patent protection, the
expiration dates and
 applicable jurisdictions. To the extent material, please also clarify
whether you or
 Merck will hold any future intellectual property related to your
Influenza A/B
 program that was developed in your prior collaboration.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Research and Development Expense, page 40

5. In future filings, beginning with your Form 10-Q for the period ended
June 30, 2025,
 please disclose the costs incurred during each period presented for each
of your key
 research and development projects. If you do not track your research and
development
 costs by project, please disclose that fact and explain why you do not
maintain and
 evaluate research and development costs by project. For costs that are
not tracked and
 disclosed by project, please provide other quantitative disclosure that
provides more
 transparency as to the type of research and development expenses
incurred (i.e. pre-
 clinical and clinical and by nature or type of expense) which should
reconcile to total
 research and development expense on the Statements of Operations.
General and Administrative Expense, page 41

6. In future filings, please revise to provide a table quantifying each
significant
 component included in general and administrative expenses, such as
 employee compensation-related costs dedicated to general and
administrative
 activities, legal fees, audit and tax fees, consultants and professional
services, and
 general corporate expenses.

 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
 July 30, 2025
Page 3

of action by the staff.

 Please contact Sasha Parikh at 202-551-3627 or Christine Torney at
202-551-3652 if
you have questions regarding comments on the financial statements and related
matters. Please contact Jessica Dickerson at 202-551-8013 or Alan Campbell at
202-551-
4224 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
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