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ORCHESTRA
BIOMED HOLDINGS, INC.

150 Union Square Drive

New Hope, Pennsylvania 18938

May 8, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Orchestra BioMed Holdings, Inc.

  Registration Statement on Form S-3, initially filed
on October 10, 2023, as amended

  File No. 333-274924

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended, Orchestra BioMed Holdings, Inc. (the “Company”) hereby respectfully requests that
the effectiveness of the Registration Statement on Form S-3 (File No. 333-274924) of the Company, initially filed with the U.S.
Securities and Exchange Commission on October 10, 2023 (as amended, the “Registration Statement”), be accelerated
so that the Registration Statement shall become effective at 4:30 p.m. (Eastern Time) on May 9, 2024, or as soon as possible
thereafter.

The Company hereby confirms that it is aware of 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 offering
of the securities specified in the Registration Statement.

It would be appreciated if, promptly after the Registration Statement
has become effective, you would so inform our outside counsel, Yariv Katz of Paul Hastings LLP, by telephone at (212) 318-6393 or by email
at yarivkatz@paulhastings.com. The Company hereby authorizes Mr. Katz of Paul Hastings LLP to orally modify or withdraw this request
for acceleration.

    Sincerely

    ORCHESTRA BIOMED
    HOLDINGS, INC.

    By:
    /s/ David P. Hochman

    Name:
    David P. Hochman

    Title:
    Chief Executive Officer

    cc:
    Yariv Katz

    Paul Hastings LLP