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CORRESP
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Eton
Pharmaceuticals, Inc.

21925
W. Field Parkway, Suite 235

Deer
Park, Illinois 60010-7208

May
1, 2023

Via
EDGAR Submission

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Arzhang Navai

    Re:
    Eton
    Pharmaceuticals, Inc.

    Registration
    Statement on Form S-3

    SEC
    File No. 333-271196

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Securities Act of 1933, as amended, Eton Pharmaceuticals, Inc. (the “Company”) hereby requests
acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-271196), as amended (the “Registration
Statement”), to 4:00 p.m. Eastern Time, Tuesday May 2, 2023 or as soon thereafter as practicable. The Company hereby acknowledges
its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate
to the proposed public offering of any securities specified in the above-referenced Registration Statement. In addition, the Company
acknowledges that:

 ● should
                                            the Securities and Exchange Commission (the “Commission”) or the staff, acting
                                            pursuant to delegated authority, declare the filing effective, it does not foreclose the
                                            Commission from taking any action with respect to the filing;

 ● the
                                            action of the Commission or the staff, acting pursuant to delegated authority, in declaring
                                            the filing effective, does not relieve the Company of its full responsibility for the adequacy
                                            and accuracy of the disclosures in the filing; and

 ● the
                                            Company may not assert staff comments and the declaration of effectiveness as a defense in
                                            any proceeding initiated by the Commission or any person under the federal securities laws
                                            of the United States.

Please
contact Geoffrey R. Morgan, counsel to the Company, at (414) 588-2948 or via email at gmorgan@crokefairchild.com, as soon as the Registration
Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

    Sincerely,

    Eton Pharmaceuticals, Inc.

    By:

    /s/
    James R. Gruber

    Chief
Financial Officer and Secretary

    (Principal
Financial Officer)

    cc:
    Geoffrey
    R. Morgan