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CORRESP
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May 22, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F. Street, N.E.

Washington, D.C. 20549

    Attn:
    Lauren Hamill

    Re:

    Alpha Cognition Inc.

    Amendment No. 1 to Registration Statement on Form S-1

    Filed May 10, 2024

    File No. 333-278997

Ladies and Gentlemen,

Alpha Cognition Inc., a British
Columbia corporation (the “Company”), hereby provides the following information in response to the comments received
from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) in
its letter to the Company dated May 21, 2024 (the “Comment Letter”). The Company’s responses are preceded by
a reproduction of the corresponding Staff comments as set forth in the Comment Letter.

In addition, if the Staff
would like hard copies of the Amendment No. 2 to the Registration Statement on Form S-1 (“Amendment No. 2”) as filed
with the Commission on the date hereof, marked against the Amendment No. 1 to the Registration Statement on Form S-1 as filed with the
Commission on May 10, 2024, please so advise and we would be happy to provide such copies. All page number references contained in the
Company’s responses below correspond to the page numbers in Amendment No. 2.

Amendment No. 1 to Registration Statement on
Form S-1

Prospectus Summary

Our Products and Approaches to Treatment, page
3

1. Please revise your pipeline table to ensure that all text, including footnotes, subscript, or other notations,
are clearly legible without the need for magnification.

Company Response: The Company
acknowledges the Staff’s comment and has revised the S-1 on page 3 of Amendment No. 2 to make the text, footnotes, subscript and
other notations clearly legible.

2. We note your response to prior comment 5, and have the following additional comment. If true, please expand
your footnotes to the pipeline table to clarify that further development of ALPHA-1062IN is dependent upon (1) the out-license of ALPHA-1062IN
for mTBI and TBI to Alpha Seven Therapeutics Inc., which out-license has not yet occurred, and (2) Alpha Seven’s ability to raise sufficient
capital resources through financing(s).

Company Response: The Company
acknowledges the Staff’s comment and has revised the S-1 on page 3 of Amendment No. 2 to clarify in the footnotes to the pipeline
table that development of ALPHA-106IN is dependent on completion of the out-licensing with Alpha Seven Therapeutics and Alpha Seven raising
sufficient capital resources through financing.

3. We note your response to prior comment 6, which we reissue with respect to your discussion of the ALPHA-1062
sublingual formulation on page 5. Please specify the material resources that you must obtain in order to advance development of this program,
and describe any plans to procure such resources, to the extent such plans have been developed.

Company Response: The Company
acknowledges the Staff’s comment and has revised the S-1 on page 5 of Amendment No. 2 to clarify that the sublingual formulation
is dependent upon receipt of additional capital resources through financing and that currently there are no specific plans for development.

Business

Our solution: Alpha-1062, page 85

4. We reissue the second and third bullets of prior comment 9 with respect to the following statement on
page 85: “According to third-party market research conducted by Infinity Group in October 2021, market research confirms that based
on the product attributes listed above, 88% of LTC prescribers are likely to prescribe ALPHA-1062, with a 29% preference share.”

Company Response: The Company
acknowledges the Staff’s comment and has revised the S-1 on page 85 of Amendment No. 2 to address the comment.

Exhibit Index, page II-8

5. In the next filing of your amended registration statement on Form S-1, please have your auditors correctly
state the Form to which their consent relates to.

Company Response: The Company
acknowledges the Staff’s comment and the auditor has revised their new consent to Amendment No. 2 to address the comment.

Should you have any further comments or questions
about Amendment No. 2 or this letter, please contact our legal counsel, Jason K. Brenkert of Dorsey & Whitney LLP at 303-352-1133
or brenkert.jason@dorsey.com. We thank you for your time and attention.

    Very truly yours,

    ALPHA COGNITION INC.

    By:
    /s/ Michael McFadden

    Michael McFadden

    Chief Executive Officer