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 March 31, 2025

Norman Staskey
Chief Financial Officer and Treasurer
Azitra, Inc.
21 Business Park Drive
Branford , CT 06405

 Re: Azitra, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 24, 2025
 File No. 001-41705
Dear Norman Staskey:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 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
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Research and Development, page 75

1. We are partially reissuing this comment, as your discussion and analysis
do not
 include the disaggregated research and development expense disclosure
that you
 agreed to provide in a prior review. Please revise future filings to
disclose whether
 you track your research and development expenses by program and/or by
product
 candidates. If so, provide a disaggregated disclosure. If not, please
disclose that fact
 along with the reason for not tracking them separately. Additionally,
consider
 providing a disaggregated disclosure by the nature of costs.
Financial Condition, page 75

2. We are reissuing this comment as we note that your liquidity discussion
and
 analysis no longer includes the known contractual obligation and
 contingency disclosures that you added during a prior review, given your
going
 March 31, 2025
Page 2

 concern and the need for future funding. Please revise future filings to
expand your
 financial condition disclosure to include a liquidity discussion that
analyzes material
 cash requirements from known contractual and other obligations,
including significant
 future lease obligations and any other contingencies. Refer to Item
303(b)(1) of
 Regulation S-K.
Critical Accounting Estimates, page 76

3. We note that you have removed all your critical accounting policies that
were
 disclosed in your prior Form 10-K for the year ended December 31, 2023
and your
 prior Form S-1 that was effective on June 15, 2023. Please enhance your
disclosures
 in future filings to provide qualitative and quantitative information
necessary to
 understand the estimation uncertainty and the impact critical accounting
estimates
 have had or are reasonably likely to have on your financial condition
and results of
 operations. The disclosures should supplement, not duplicate, the
description of
 accounting policies or other disclosures in the notes to the financial
statements. Refer
 to Item 303(b)(3) of Regulation S-K and SEC Release No. 33-8350.
Item 8. Financial Statements and Supplementary Data - Notes to Financial
Statements
2. Summary of Significant Accounting Policies, page F-9

4. Please provide segment information in the footnotes of future filings as
required by
 ASU 2023-07 and ASC 280-10-50, or explain why you believe that you are
not
 subject to this accounting standard.
17. Subsequent Events, page F-26

5. We note your February 20, 2025 Form 8-K discloses your stockholders
approved a
 reverse stock split prior to the February 24, 2025 date of your audit
opinion. Please
 revise future filings to clearly state the status and timing of the
board's approval of
 your reverse stock split, and indicate whether the financial statements
have been
 adjusted to reflect this effect.
 In closing, 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 of action by the staff.

 Please contact Bonnie Baynes at 202-551-4924 or Daniel Gordon at
202-551-3486
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
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