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Response Letter

December 19, 2022

 +1 617 526 6000 (t)

+1 617 526 5000 (f)

wilmerhale.com

 By Electronic Submission

Securities and Exchange Commission

Division of Corporation Finance

 100 F
Street, N.E.

 Washington, DC 20549

Attention:

    Jenn Do

    Kevin Vaughn

    Lauren Hamill

    Tim Buchmiller

 Re:     Imara Inc.

          Registration Statement on Form S-4

          Filed November 10, 2022

          File No. 333-268300

Ladies and Gentlemen:

 On behalf of Imara Inc. (the
“Company”), we are responding to the comments contained in a letter, dated December 7, 2022 (the “Letter”) from the Staff (the “Staff”) of the Office of Life Sciences of the Division of
Corporation Finance of the Securities and Exchange Commission (the “Commission”) to Rahul Ballal, Ph.D., the Company’s President and Chief Executive Officer, relating to the above referenced Registration Statement on Form S-4 (the “Registration Statement”). The Company is concurrently filing Amendment No.1 to the Registration Statement on Form S-4 (the “Amended
Registration Statement”), which includes changes to reflect responses to the Staff’s comments and other updates.

 For reference purposes,
the Staff’s comments as set forth in the Letter have been reproduced and italicized herein. The responses are keyed to the numbering of the comments and the headings used in the Letter. Unless otherwise indicated, the page references in the
reproduction of the Staff’s comments refer to the Registration Statement, and the page references in the response refer to the Amended Registration Statement. The responses are based upon information provided to Wilmer Cutler Pickering Hale and
Dorr LLP by the Company. Where appropriate, the Company has responded to the Staff’s comment by making changes to the disclosure in the Registration Statement. All capitalized terms used and not otherwise defined herein shall have the meanings
set forth in the Amended Registration Statement.

 Wilmer Cutler Pickering Hale and Dorr LLP, 60 State Street, Boston,
Massachusetts 02109

Beijing    Berlin    Boston    Brussels    Denver
  Frankfurt    London    Los Angeles    New York    Palo Alto    San Francisco    Washington

December 19, 2022

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 Registration Statement on Form S-4 filed November 10, 2022

 Questions and Answers about the Merger

 Will
the common stock of the combined company trade on an exchange?, page 4

1.
 Please revise your disclosure as follows:

•

 Disclose, as you have on page 197, that Imara has agreed to cause the shares of Imara common stock being
issued in the Merger to be approved for listing on Nasdaq at or prior to the effective time. State both here, on page 197 and elsewhere as appropriate, as you have in Article VII of the Merger Agreement, that the approval for listing these shares on
Nasdaq, subject to official notice of issuance, is a closing condition of the Merger. Also disclose whether the terms of the merger agreement permit that this closing condition could be waived without recirculation or resolicitation. In this regard,
we note that disclosure on page 197 and 212 seems to indicate that this condition is waivable.

•

 You disclose that Enliven has filed a listing application for the combined company’s common stock with
Nasdaq and that it is “expected” that the common stock of the combined company will trade on The Nasdaq Stock Market. Please revise here and on pages 23 and 197, and elsewhere as appropriate, to make clear whether the merger is conditioned
upon receiving Nasdaq listing approval for the combined company, and if so, whether such condition is waivable. State whether Nasdaq’s determination in this regard will be known at the time that stockholders are asked to vote to approve the
business combination. Please also include a cross-reference to your risk factor disclosure stating that the potential reverse stock split may not result in an increase in the combined company’s stock price necessary to satisfy Nasdaq’s
initial or continued listing requirements for the combined company.

•

 Disclose here, in your risk factor disclosure on page 32, and elsewhere as appropriate, whether or not you
satisfy the objective Nasdaq listing criteria, and if not, explain which requirement(s) your stock does not currently meet for listing and describe your plan to remedy. In your risk factor disclosure, explain how the reverse stock split is intended
to cause you to be in compliance.

Response:
 With respect to bullet 1, the Company respectfully advises the Staff that it has revised the disclosures in the
letter to stockholders at the beginning of the Amended Registration Statement and on pages 4, 205, 206 and 220 of the Amended Registration Statement in response to the Staff’s comment.

With respect to bullet 2, the Company respectfully advises the Staff that it has revised the disclosures in the letter to stockholders at the
beginning of the Amended Registration Statement and on pages 4, 24, 35, 205 and 206 of the Amended Registration Statement in response to the Staff’s comment.

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 With respect to bullet 3, the Company respectfully advises the Staff that it has revised the
disclosures in the letter to stockholders at the beginning of the Amended Registration Statement and on pages 4, 24, 35, 205, 206, and 256 of the Amended Registration Statement in response to the Staff’s comment.

What are the material U.S. federal income tax consequences of the Merger to Enliven U.S. holders?, page 7

2.
 We note your representation here and beginning on page 195 that Imara and Enliven “intend” the
merger to qualify as a reorganization within the meaning of Section 368(a) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”), and/or a non-taxable exchange
transaction governed by Section 351(a) of the Code. Please revise your disclosure here and throughout to provide counsel’s firm opinion for each material tax consequence, including whether the Merger will qualify as a
reorganization and/or a nontaxable exchange transaction, or to explain why such opinion cannot be given. If the opinion is subject to uncertainty, please (1) provide an opinion that reflects the degree of uncertainty (e.g.,
“should” or “more likely than not”) and explains the facts or circumstances giving rise to the uncertainty, and (2) provide disclosure of the possible alternative tax consequences including risk factor and/or
other appropriate disclosure setting forth the risks of uncertain tax treatment to investors. Please refer to Item 601(b)(8) of Regulation S-K and Section III.A. of Staff Legal Bulletin 19, Legality and Tax
Opinions in Registered Offerings.

Response:
 The Company respectfully advises the Staff that it has revised the disclosures on pages 7, 8, 21, 22,
34, 180, 181, 201, 202, 203 and 204 of the Amended Registration Statement in response to the Staff’s comment. In addition, the Company advises the Staff that counsel to each of the Company and Enliven will deliver respective opinions responsive
to the Staff’s comment, and such opinions will be filed by amendment to the Registration Statement.

 Prospectus Summary

 The Companies, page 9

3.
 We note your statement that Enliven’s goal is to design best-in-class or first-in-class therapies, and other similar statements throughout such as those indicating that
“Enliven’s product candidates will be aimed to be best-in-class and
first-in-class.” Given the development stage of Enliven’s product candidates and length of the drug approval process, it is premature and inappropriate to
speculate or imply that any Enliven product candidates will ultimately be approved or become best-in-class or first-in-class. Please remove these statements.

December 19, 2022

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Response:
 The Company respectfully advises the Staff that it has revised the disclosures on pages 10, 11, 90, 101,
288, 290, 291, 294, 297, 298, 366, F-7 and F-30 of the Amended Registration Statement in response to the Staff’s comment.

Enliven’s Pipeline, page 11

4.
 Please clarify what the “Differentiation” column in the pipeline table is intended to convey. In
addition, we note you have created a distinction between “lead optimization” and “IND-enabling.” Please explain what is involved in “lead optimization” and why you believe this is
a separate and distinct development phase, as opposed to part of discovery and/or IND-enabling studies, or revise.

Response:
 The Company respectfully advises the Staff that it has revised the pipeline table on pages 11, 291 and
366 of the Amended Registration Statement in response to the Staff’s comment to remove the “Differentiation” column and revise the title of the “Lead Optimization” column to “Discovery.” The Company also
respectfully advises the Staff that it has changed “lead optimization” to “discovery” on pages 290, 293 and 297 of the Amended Registration Statement.

Support Agreements, page 17

5.
 We note your discussion of the support agreements beginning on pages 17 and 219.

•

 Please tell us with specificity who signed the support agreements, and show us how the percentages of
securities covered are reconcilable to the beneficial ownership disclosure on pages 415-423.

•

 We also note the discussion of irrevocable proxies in the disclosure and in section 7 of Exhibit 2.3, which is
incorporated by reference to your Form 8-K filed October 13, 2022. Please provide us your analysis supporting your conclusions regarding whether offers and sales of the securities registered
for sale have already been made and completed. For guidance, see the Division of Corporation Finance’s Securities Act Sections Compliance and Disclosure Interpretation 239.13 available on the Commission’s website.

Response:
 The Company respectfully advises the Staff that it has revised the disclosure on page 227 of the Amended
Registration Statement in response to the Staff’s comment to specify the signatories for the support agreements.

The Enliven stockholders who are signatories to the support agreements are as follows: Richard Heyman and certain affiliated trusts, entities
affiliated with 5AM Ventures, Samuel Kintz and certain affiliated trusts, Jake Bauer, Helen Collins, Cormorant, Mika Derynck, Anish Patel and certain affiliated trusts, Benjamin Hohl, Joseph P. Lyssikatos and certain affiliated trusts, entities
affiliated with OrbiMed, Roche Finance Ltd, and Sheatree Direct, LLC. For purposes of this

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paragraph, beneficial ownership has been calculated in accordance with the SEC rules regarding beneficial ownership as described on page 434 of the Amended Registration Statement and based on
78,102,987 shares of Enliven’s common stock outstanding, which consists of 73,788,648 shares of Enliven’s common stock outstanding and 4,314,339 shares subject to options exercisable within 60 days of October 15, 2022. The Company
respectfully advises the Staff that the entity investor holders that executed support agreements collectively beneficially own approximately 69.08% of the outstanding voting equity of Enliven, of which 64.43% is represented on the “Principal
Stockholders of Enliven” disclosure that appears on page 434 of the Amended Registration Statement (the “Enliven Beneficial Ownership Table”). Sheatree Direct, LLC, which is a sophisticated, accredited investor owning 4.92% of
the outstanding voting securities of Enliven, and has a designated nonvoting observer that attends meetings of the board of directors of Enliven, is the sole entity investor signatory to a support agreement that does not appear on the Enliven
Beneficial Ownership Table. The directors, executive officers and their affiliated trusts that executed support agreements collectively beneficially own approximately 71.83% of the outstanding voting equity of Enliven, of which 70.93% is represented
on the Enliven Beneficial Ownership Table. The Miller L. Lyssikatos Irrevocable Trust, dated October 30, 2021 and the Peter J. Lyssikatos Irrevocable Trust, dated October 30, 2021, trusts affiliated with Joseph Lyssikatos, a co-founder and director of Enliven, holding 0.64% of the outstanding voting securities of Enliven, are signatories to the support agreements that do not appear on the Enliven Beneficial Ownership Table because the
shares held by such trusts are not attributable to Joseph Lyssikatos pursuant to the SEC rules regarding beneficial ownership. The Dylan Minh-Hanh Patel Irrevocable Trust, dated October 30, 2021, and the Ellie Dieu-Lien Patel Irrevocable Trust,
dated October 30, 2021, trusts affiliated with Anish Patel, a co-founder and executive officer of Enliven, holding 0.26% of the outstanding voting securities of Enliven, are signatories to the support
agreements that do not appear on the Enliven Beneficial Ownership Table because the shares held by such trusts are not attributable to Anish Patel. The shares beneficially owned by Anish Patel are only included in the “All current executive
officers and directors as a group” line in the Enliven Beneficial Ownership Table because Anish Patel is not a named executive officer of Enliven.

For purposes of this paragraph, beneficial ownership has been calculated in accordance with the SEC rules regarding beneficial ownership as
described on page 431 of the Amended Registration Statement and based on 27,340,785 shares of Imara’s common stock outstanding, which consists of 26,287,264 shares of Imara common stock outstanding and 1,053,521 shares subject to options
exercisable within 60 days of October 15, 2022. The stockholders of the Company who are signatories to the support agreements are as follows: Arix Bioscience, Barbara

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Dalton, David Bonita, David M. Mott, Edward Connor, Carl Goldfischer, Laura Williams, Mark Chin, Michael Gray, an entity affiliated with OrbiMed, an entity affiliated with Pfizer, and Rahul
Ballal. The Company respectfully advises the Staff that the Company stockholders that executed support agreements collectively beneficially own approximately 37.6% of the outstanding voting equity of the Company, all of which is represented in the
“Principal Stockholders of Imara” disclosure that appears on page 431 of the Amended Registration Statement.

 For purposes of
this paragraph, beneficial ownership has been calculated in accordance with the SEC rules regarding beneficial ownership as described on page 437 of the Amended Registration Statement and based on 180,971,237 shares of combined company common stock
expected to be outstanding upon consummation of the Merger, which consists of 175,282,231 shares of combined company common stock expected to be outstanding upon the consummation of the Merger and 5,689,006 shares subject to options exercisable
within 60 days of October 15, 2022. The Company respectfully advises the Staff that the stockholders who are signatories to the support agreements and are also reflected in the “Principal Stockholders of the Combined Company” disclosure
that appears on page 437 of the Amended Registration Statement (the “Combined Company Beneficial Ownership Table”) include Richard Heyman and certain affiliated trusts, entities affiliated with 5AM Ventures, Samuel Kintz and certain
affiliated trusts, Jake Bauer, Helen Collins, Mika Derynck, Benjamin Hohl, Joseph P. Lyssikatos and certain affiliated trusts, entities affiliated with OrbiMed, and Rahul Ballal. The Company respectfully advises the Staff that the stockholders that
executed support agreements are expected to collectively beneficially own approximately 50.14% of the outstanding voting equity of the combined company, of which 42.00% is represented in the Combined Company Beneficial Ownership Table. The shares
beneficially owned by Anish Patel are only included in the “All current executive officers and directors as a group” line in the Combined Company Beneficial Ownership Table because Anish Patel will not be a named executive officer of the
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