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CORRESP
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 CORRESP

 Divakar Gupta T:
 (212) 479-6474 dgupta@cooley.com
 August 22, 2025 U.S. Securities and Exchange Commission
 Division of Corporation Finance Office of Life Sciences
 100 F Street, N.E. Washington, D.C. 20549

 Attention:
 Christine Torney

  
 Mary Mast

  
 Doris Stacey Gama

  
 Laura Crotty

 Re:
 LB Pharmaceuticals Inc

  
 Amendment No.2 to Draft Registration Statement on Form S-1

  
 Submitted on July 23, 2025

  
 CIK No. 0001691082
 Ladies and Gentlemen: On behalf of LB Pharmaceuticals Inc (the
“ Company ”), the following information is submitted in response to the comments received from the staff (the “ Staff ”) of the U.S. Securities and Exchange Commission (the
“ Commission ”) by letter dated August 12, 2025 (the “ Comment Letter ”) regarding the above-referenced Amendment No.2 to the draft Registration Statement on Form
 S-1, as confidentially submitted to the Commission on July 23, 2025. Concurrently with the submission of this response letter, the Company is filing a revised Registration Statement on Form S-1 (the “ Registration Statement ”) with the Commission. In addition to addressing the comments raised by the Staff in the Comment Letter, the Company has included other revisions and
updates to its disclosure in the Registration Statement. For the convenience of the Staff, the numbering of the paragraphs below corresponds to the
numbering of the respective comment in the Comment Letter, the text of which we have incorporated into this response letter for convenience in italicized type and which is followed by the Company’s response. In the responses below, page number
references are to the Registration Statement. Amendment No. 2 to Draft Registration Statement on Form
 S-1 Prospectus Summary
 Overview, page 1:

 1.
 You state that based on positive
 end-of-Phase 2 feedback from the FDA, as well as historical precedent, you believe that your Phase 2 acute schizophrenia trial may serve as one of the two pivotal trials
required for approval of a new drug application and therefore would only need a single, six-week Phase 3 trial alongside other planned NDA-enabling studies for approval.
Please balance this disclosure by also stating that there is no guarantee that your Phase 2 trial may serve as one of the two pivotal trials required which in such case you may be required to conduct two pivotal trials for NDA approval.
 Response: In response to the Staff’s comment, the Company has revised the disclosures on pages 2, 113 and
137 of the Registration Statement.
 Cooley LLP 55 Hudson
Yards, New York, NY 10001-2157 t: (212) 479-6000 f: (212)
 479-6275 cooley.com

 U.S. Securities and Exchange Commission
 August 22, 2025 Page Two

 Business, page 110:

 2.
 We note your use of p-values throughout this section regarding your
product candidate LB-102. At first use, please provide a brief explanation of the disclosed p-value and how it is used to measure statistical significance.
 Response: In response to the Staff’s comment, the Company has revised the disclosures on page 128 of the
Registration Statement. * * * Please
contact me at (212) 479-6474 with any questions or further comments regarding our responses to the Staff’s comments.
 Sincerely, /s/ Divakar Gupta
 Divakar Gupta cc:  
 Heather Turner, LB Pharmaceuticals Inc
 Gad Soffer, LB Pharmaceuticals Inc
 Marc Panoff, LB Pharmaceuticals Inc
 Brandon Fenn, Cooley LLP Marc
Recht, Cooley LLP Minkyu Park, Cooley LLP
 Cooley LLP 55 Hudson
Yards, New York, NY 10001-2157 t: (212) 479-6000 f: (212)
 479-6275 cooley.com