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CORRESP
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 NLS Pharmaceutics Ltd.

 The Circle 6

 8058 Zurich, Switzerland

 September 3, 2025

 Via EDGAR

 Angela Connell

 Eric Atallah

 Doris Stacey Gama

 Alan Campbell

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Life Sciences

 100 F Street, NE

 Washington, DC 20549

 Re: NLS
Pharmaceutics Ltd. (the "Company," "we," "our" and similar terminology)

 Correspondence Submitted August 15, 2025
Amendment No. 6 to Registration Statement on Form F-4
File No. 333-284075

 Ladies and Gentlemen:

 The purpose of this letter is to respond to the
comment letter of August 28, 2025, received from the staff (the "Staff") of the U.S. Securities and Exchange Commission regarding
the above-mentioned Correspondence Submitted August 15, 2025 regarding Amendment No. 6 to the Registration Statement on Form F-4. For
your convenience, your original comments appear in bold text, followed by our response. We are concurrently filing Amendment No. 7 to
the Registration Statement on Form F-4.

 Unless otherwise stated, any defined terms in
Amendment No. 7 apply within this letter.

 Amendment No. 6 to Registration Statement
on Form F-4

 Record Date; Outstanding Shares; Shareholders
Entitled to Vote, page 105

 1. We
note from your responses to prior comment 1 and 2 that your reference to "treasury shares" is under Swiss corporate law rather
than U.S. GAAP. In instances where terms have different meanings under Swiss corporate law and U.S. GAAP, please clearly disclose
that you are referring to Swiss corporate law. Briefly explain the requirements under the Swiss corporate law and clearly
indicate that you are referring to amounts calculated in accordance with Swiss corporate law and that such amounts differ from amounts
calculated under U.S. GAAP.

 Response: In response to the Staff's
comment, and in reference to our prior responses in prior comments 1 and 2, under Swiss corporate law, shares held by the Company itself,
even if never transferred to external parties, are considered issued and "warehoused" for future financings and are reflected
as such in the Swiss share registry. Under Swiss corporate law, these holdings are referred to as "treasury shares."

 In response to the Staff's comment, we have
revised the Registration Statement on Form F-4 to clarify that references to "treasury shares" are made in the context of
Swiss corporate law, to briefly describe the relevant Swiss corporate law requirements, and to state that such amounts differ from those
calculated under U.S. GAAP.

 NLS Pharmaceutics Ltd. and Subsidiaries

 Consolidated Balance Sheets, page F-4

 2. We
note your response to prior comment 6. We do not agree that the error in the preferred and common share line items on the
face of your Consolidated Balance Sheet is immaterial. Accordingly, please revise your Registration Statement on Form F-4
to correct this error in your Consolidated Balance Sheet and remove the related pro forma adjustment.

 Response: In response to the Staff's
comment, we have revised the Consolidated Balance Sheets on page F-4 of the Registration Statement on Form F-4 to correct the presentation
of preferred and common shares. The related pro forma adjustment has been removed.

 If you have any questions or require additional
information, please contact our attorneys Ron Ben-Bassat, Esq. at (212) 660-5003 or Oded Har-Even, Esq. at (212) 660-5002, each of Sullivan
& Worcester LLP.

 Sincerely,

 NLS Pharmaceutics LTD.

 By:
 /s/ Alexander Zwyer

 Chief Executive Officer