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CORRESP
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CORRESP

 Contineum Therapeutics, Inc.

10578 Science Center Drive, Suite 200

San Diego, CA 92121

 The entity requesting
confidential treatment is:

 Contineum Therapeutics, Inc.

10578 Science Center Drive, Suite 200

 San Diego, CA 92121

Attn: Peter Slover

 Chief Financial Officer

(858) 333-5280

CERTAIN PORTIONS OF THIS LETTER HAVE BEEN OMITTED FROM THE VERSION FILED VIA EDGAR. CONFIDENTIAL TREATMENT HAS BEEN REQUESTED WITH RESPECT TO THE OMITTED
PORTIONS. INFORMATION THAT WAS OMITTED IN THE EDGAR VERSION HAS BEEN NOTED IN THIS LETTER WITH A PLACEHOLDER IDENTIFIED BY THE MARK “[*].”

March 20, 2024

 Via EDGAR

Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Life Sciences

 100 F Street, N.E.

Washington, D.C. 20549

Attn:

Daniel Crawford

Laura Crotty

Ibolya Ignat

Kevin Juhar

Re:

Contineum Therapeutics, Inc.

Registration Statement on Form S-1

Filed March 15, 2024

File No. 333-278003

CIK No: 0001855175

 Ladies and Gentlemen:

Contineum Therapeutics, Inc. (the “Company”, “we”, “our”, or
“us”), in response to comments from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) received by letter dated January 11, 2024 (the
“Comment Letter”), relating to the Company’s Draft Registration Statement on Form S-1 confidentially submitted to the Commission on December 13, 2023, which was subsequently
updated by the Company with amendment No. 1 to the draft registration statement on Form

 1

S-1 confidentially submitted via EDGAR to the Commission on January 29, 2024, amendment No. 2 to the draft registration statement on Form S-1 confidentially submitted via EDGAR to the Commission on February 15, 2024 and a registration statement on Form S-1 filed with the Commission on March 15, 2024
(collectively, the “Registration Statement”), is submitting this supplemental letter to further address comment 10 of the Comment Letter. For the convenience of the Staff, the Company has incorporated the text
of comment 10 into this letter.

 Confidential Treatment Request

The Company hereby requests, pursuant to 17 C.F.R. §200.83, that certain portions of this letter be maintained in confidence, not be made
part of any public record and not be disclosed to any person. The Company has filed a separate copy of this letter, marked to show the portions redacted from the version filed via EDGAR and for which the Company is requesting confidential treatment.
In accordance with 17 C.F.R. §200.83(d)(1), if any person (including any governmental employee who is not an employee of the Commission) should request access to or an opportunity to inspect this letter, the Company requests that it be
immediately notified of any such request, be furnished with a copy of all written materials pertaining to such request (including, but not limited to, the request itself) and be given at least ten business days’ advance notice of any intended
release so that the Company may, if it deems it to be necessary or appropriate, pursue any remedies available to it. In such an event, the Company requests that you telephone the undersigned at 858-524-3061 rather than rely on the U.S. mail for such notice.

 Staff Comment:

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies and Significant Judgments and Estimates

Stock-Based Compensation Expense and Common Stock Valuation, page 108

10.
 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 initial public offering and the estimated offering price. This information will help
facilitate our review of your accounting for equity issuances including stock compensation. Please discuss with the staff how to submit your response.

Response:

 The Company respectfully
submits the below additional information to assist the Staff in its review of the Company’s determination of the fair value of its common stock (“Common Stock”) underlying its outstanding equity awards, including the
changes in the valuation of its Common Stock from January 2022 to March 2024.

 Preliminary IPO Price Range

The Company advises the Staff that the Company currently expects a price range of approximately $[*] to $[*] per share (the Preliminary
Price Range”) with a midpoint of the anticipated Preliminary Price Range of approximately $[*] per share for the proposed initial public offering (“IPO”) of the Company’s common stock, par value $0.0001 per
share (the “Common Stock). The Company also advises the Staff that it expects to reflect a reverse stock split on a [*]:1.00 basis (the “Reverse Stock Split”) that the Company plans to effect prior to the
commencement of the “road show” for the proposed offering, which will be disclosed in a pre-effective amendment to the Registration Statement that includes the estimated Preliminary Price Range;
however, all dollar amounts and per share amounts in this letter do not take into account the Reverse Stock Split.

 2

 The Preliminary Price Range is based in part upon the Company’s financial information,
history and prospects, prospects for the biopharmaceutical industry, an assessment of the Company’s management, its past and present operations, and the prospects for, and timing of, its future revenues, the present state of the Company’s
development, the general condition of the securities markets and the recent market prices of, and the demand for, publicly traded shares and valuation multiples of generally comparable companies in the biopharmaceutical industry, as well as input
received in testing-the-waters meetings with investors and from Goldman Sachs & Co. LLC and Morgan Stanley & Co. LLC (the
“Representatives”) as the representatives of the several underwriters for the Company’s IPO. The Company notes that, as is typical in IPOs, the Preliminary Price Range for the Company’s IPO was not derived using a
formal determination of fair value, but was determined by discussions between the Company and the Representatives based on the assessment of the foregoing factors.

However, the parameters of the actual bona fide price range will be subject to then-current market conditions, continuing discussions with the
Representatives and any material developments impacting the Company. Also, due to the volatility in the capital markets, in particular the volatility experienced in the market by recent IPO issuers, there is a possibility that the actual bona fide
price range for the IPO may fall outside of the Preliminary Price Range (after giving effect to the Reverse Stock Split). In any event, the Company confirms to the Staff that the bona fide price range will comply with Item 501(b)(3) of Regulation S-K and C&DI 134.04. The Company’s final post-split bona fide price range remains under discussion between the Company and the Representatives, and a bona fide price range will be included in an amendment
to the Registration Statement prior to any distribution of the preliminary prospectus in connection with the Company’s road show.

 Stock Option
Grants Since January 2022

 The Company has periodically granted equity awards, exclusively in the form of stock options, to certain
of its employees, directors, and consultants. The Company accounts for equity-based compensation in accordance with ASC 718 Compensation—Stock Compensation (“ASC 718”). In accordance with ASC 718, the Company estimates
the fair value of stock options as of the date of grant, using the Black-Scholes option pricing model (“Black-Scholes”). The Black-Scholes assumptions include the fair value of common shares, expected term of the option, the
expected volatility of the stock price, the expected dividend rate, and the risk-free interest rate during the expected term of the option.

The Company recognizes this estimated value of granted stock options as compensation expense over the contractual vesting period, during which
substantive services are provided in exchange for the award. From January 1, 2022 through March 20, 2024, the Company granted stock options, as follows:

 Stock Option Grant Date

Number of
Options
Granted

Exercise
Price

Fair Value Per Share of
Common Stock
on Grant Date under
409A Valuation Report

 December 7, 2022

166,675

$
1.34

$
1.34

 March 24, 2023

50,000

$
1.89

$
1.89

 September 27, 2023

265,000

$
1.93

$
1.93

 October 9, 2023

2,887,000

$
1.93

$
1.93

 October 31, 2023

60,000

$
2.05

$
2.05

 December 5, 2023

48,000

$
2.05

$
2.05

 3

 Historical Fair Value Determination and Methodology

As there has been no public market for the Company’s Common Stock to date, the estimated fair value of Common Stock for purposes of
granting equity awards has been determined by the Company’s board of directors (the “Board”), and the Board has estimated the fair value of the Common Stock at various grant dates, with input from management, considering
our most recently available third-party valuation of Common Stock by the applicable valuation firm (the “Valuation Firm”). All options to purchase shares of our Common Stock are intended to be granted with an exercise price
per share no less than the fair value per share of our Common Stock underlying those options on the date of grant, based on the information known to us on the date of grant.

Our determination of the value of our Common Stock was performed using methodologies, approaches and assumptions consistent with the American
Institute of Certified Public Accountants (“AICPA”), Audit and Accounting Practice Aid Series: Valuation of Privately Held Company Equity Securities Issued as Compensation (the “AICPA Practice Aid”).
In addition, our Board considered various objective and subjective factors to determine the fair value of our Common Stock at each grant date, including:

•

 valuations of our Common Stock performed by independent third-party valuation specialists;

•

 the anticipated capital structure that will directly impact the value of the currently outstanding securities;

•

 our results of operations and financial position;

•

 the status of our research and development efforts;

•

 the regulatory and clinical status of our product candidates;

•

 the composition of, and changes to, our management team and board of directors;

•

 the lack of liquidity of our common stock as a private company;

•

 our stage of development and business strategy and the material risks related to our business and industry;

•

 external market conditions affecting the life sciences and biotechnology industry sectors;

•

 U.S. and global economic conditions;

•

 the likelihood of achieving a liquidity event for the holders of our Common Stock, such as an initial public
offering, or a sale of our company, given prevailing market conditions; and

•

 the market value and volatility of comparable companies.

 4

 The AICPA Practice Aid prescribes several valuation approaches for setting the value of an
enterprise, such as the cost, income and market approaches, and various methodologies for allocating the value of an enterprise to its common stock. The cost approach establishes the value of an enterprise based on the cost of reproducing or
replacing the property less depreciation and functional or economic obsolescence, if present. The income approach establishes the value of an enterprise based on the present value of future cash flows that are reasonably reflective of our future
operations, discounting to the present value with an appropriate risk adjusted discount rate or capitalization rate. The market approach is based on the assumption that the value of an asset is equal to the value of a substitute asset with the same
characteristics.

 In accordance with the AICPA Practice Aid, we considered the various methods for allocating the enterprise value to
determine the fair value of our Common Stock at the applicable valuation date. Under the option pricing method (“OPM”), shares are valued by creating a series of call options with exercise prices based on the liquidation
preferences and conversion terms of each equity class. The value of the common stock is inferred by analyzing these options. The probability weighted expected return method (“PWERM”) is a scenario-based analysis that
estimates the value per share based on the probability-weighted present value of expected future investment returns, considering each of the possible outcomes available to us, as well as the economic and control rights of each share class.

Based on our early stage of development and other relevant factors, we determined, based on the third-party valuation by the Valuation Firm,
that a Hybrid Method was the most appropriate method for allocating our equity value to determine the estimated fair value of our Common Stock for valuations performed from January 1, 2022 through March 20, 2024. The Hybrid Method is a
hybrid between the PWERM and OPM, estimating the probability-weighted value across multiple scenarios but using the OPM to estimate the allocation of value within one or more of those scenarios. The Hybrid Method can be useful alternative to
explicitly modeling all PWERM scenarios in situations when the company has transparency into one or more near-term exits but is unsure about what will occur if the current plans fall through. In determining the estimated fair value of our Common
Stock, our Board also considered the fact that our stockholders could not freely trade our Common Stock in the public markets. Accordingly, we applied discounts to reflect the lack of marketability of our Common Stock based on the weighted-average
expected time to liquidity.

 The measurement dates of our valuations, date of Board approval, and the per share fair value of our Common
Stock since January 1, 2022 is set forth below:

 Measurement Date of Third-Party Valuation

Date of Board
approval

Per Share Fair Value
of Common stock *

 September 30, 2022

December 7, 2022

$
1.34

 December 31, 2022

March 24, 2023

$
1.89

 June 30, 2023

September 27, 2023

$
1.93

 October 16, 2023

November 29, 2023

$
2.05

*
 Fair value determined by Board on date of Board approval.

Set forth below in this letter is a discussion of each valuation the Company has performed to date and stock option grants from
January 1, 2022 through March 20, 2024.

 5

 Discussion of Common Stock Valuations and Stock Option Grants

3rd Quarter 2022 Valuation and 4th Quarter 2022
Stock Option Grants

 September 30, 2022 Valuation

Effective September 30, 2022, the Company obtained an independent third-party 409A valuation (“September 2022
Valuation”). In December 2022, the Board, considering the September 2022 Valuation, determined the estimated fair value of Common Stock.

The valuation used the Hybrid Method where four scenarios were examined; two stay private scenarios and two IPO scenarios. We applied the OPM
to allocate value in the stay-private scenarios and PWERM to determine the value of each class of the Company’s capital stock in the IPO scenarios. Under the stay private scenarios, the equity value was determined using the precedent
transaction method under the market approach based on the Series C preferred stock financing which was completed in February 2021. The valuation applied a Discount for Lack of Marketability (“DLOM”) of 30% under the stay
private scenarios. Under the IPO scenarios, we estimated the present value of the Common Stock upon an IPO. Under the Hybrid Method, a combined 90% weighting was applied to the two stay private scenarios and a combined 10% to the two IPO scenarios.
Other factors considered by the Board in the valuation of the Common Stock as of September 30, 2022 included, among others: the September 2022 Valuation; the early status and the risks associated with the product development plan