SecProbe.io

December 17, 2018
Mark Currie
President
Cyclerion Therapeutics, Inc.
301 Binney Street
Cambridge, MA 02142
Re:Cyclerion Therapeutics, Inc.
Amendment No. 1 to Draft Registration Statement on Form 10
Submitted on December 6, 2018
CIK 0001755237
Dear Dr. Currie:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form 10 submitted December 6, 2018
Exhibit 99.1
Information Statement Summary
Cyclerion
Overview, page 12
1.We note your response to comment 5 and your disclosure that you intend to out license
praliciguat to a “leader in cardiometabolic diseases.” Please revise your disclosure to
remove the implication that you have a prospective agreement with a licensee or
collaboration partner for this product candidate. Alternatively, please tell us the basis for
this statement.

 FirstName LastNameMark Currie
 Comapany NameCyclerion Therapeutics, Inc.
 December 17, 2018 Page 2
 FirstName LastName
Mark Currie
Cyclerion Therapeutics, Inc.
December 17, 2018
Page 2
Unaudited Pro Forma Combined Financial Statements
Notes to Unaudited Pro Forma Combined Financial Data, page 65
2.Regarding pro forma adjustment (C), you include the shares to be issued in the intended
private placement in determining the number of Cyclerion shares of common stock used
to compute basic earnings per share. Please tell us how you determined that the private
placement is factually supportable and directly attributable to the separation transaction.
Please also tell us how you determined that it was appropriate to include these shares in
your pro forma EPS calculation given that the proceeds from the issuance of these shares
are not reflected as an adjustment in your pro forma Statement of Operations.
Business
Praliciguat for Cardiometabolic Diseases
Our Solution, page 96
3.We note your response to comment 8 and your disclosure that results of your Phase 2a
study of praliciguat suggested that patients had improvements in insulin sensitivity and in
endothelial function. Please revise your disclosure to remove the implication that
treatment with praliciguat resulted in the measurements cited.  You may describe any
objective observations from the trials without indicating that praliciguat is responsible for
these observations.
            You may contact Sasha Parikh at 202-551-3627 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Christine Westbrook at 202-551-5019 or Suzanne Hayes at 202-551-3675 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Will Michener, Esq.