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April 27, 2020
Tahir Mahmood, Ph.D.
Chief Executive Officer
Applied Molecular Transport Inc.
1 Tower Place, Suite 850
South San Francisco, California 94080
Re:Applied Molecular Transport Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Confidentially Submitted on April 10, 2020
CIK No. 0001801777
Dear Mr. Mahmood:
            We have reviewed your amended draft registration statement and have the following
comment.  In our comment, 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 comment applies 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 this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies, Significant Judgments and Use of Estimates
Stock-Based Compensation Expense, page 93
1.Once you have an estimated offering price or range, please explain to us how you
determined the fair value of the common stock underlying your equity issuances and the
reasons for any differences between the recent valuations of your common stock leading
up to the IPO and the estimated offering price. This information will help facilitate our
review of your accounting for equity issuances including stock compensation and
beneficial conversion features.

 FirstName LastNameTahir Mahmood, Ph.D.
 Comapany NameApplied Molecular Transport Inc.
 April 27, 2020 Page 2
 FirstName LastName
Tahir Mahmood, Ph.D.
Applied Molecular Transport Inc.
April 27, 2020
Page 2
            You may contact David Burton at 202-551-3626 or Vanessa Robertson at 202-551-3649
if you have questions regarding comments on the financial statements and related
matters.  Please contact Jessica Livingston at 202-551-3448 or Michael Clampitt at 202-551-
3434 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences