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August 13, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Tracie Mariner

    Kevin Vaughn

    Benjamin Richie

    Abby Adams

    Re:
    Polyrizon Ltd.

Amendment No. 5 to Registration Statement on Form F-1

Filed May 20, 2024

File No. 333-266745

Dear Sir or Madam:

On behalf of Polyrizon Ltd.
(the “Company”), we are writing to submit the Company’s responses to the comments of the staff (the “Staff”)
of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) dated June 14, 2024, relating
to the above referenced Registration Statement on Form F-1 (File No. 333-266745) submitted by the Company on May 20, 2024 (the “Registration
Statement”).

Concurrent with the submission
of this letter, the Company is filing via EDGAR Amendment No. 6 to the Registration Statement on Form F-1 (“Amendment No. 6”),
which reflects the Company’s responses to the comments received by the Staff and certain updated information. For your convenience,
the Company is also delivering via email a copy of this letter and the Registration Statement marked to indicate changes from the Registration
Statement.

For ease of review, we have
set forth below each of the numbered comments of your letter and the Company’s responses thereto. Capitalized terms used herein
but not defined herein have the meanings given to such terms in the Registration Statement.

Amendment No. 5 to Registration Statement on Form F-1

Cover Page

    1.

    Please revise the initial public offering
to include the volume of securities you intend to register.

Response: In response to the Staff’s
comment, the Company has revised its initial public offering on the cover page of the Amendment No. 6 to include the volume of securities
the Company intends to register.

Use of Proceeds, page 63

    2.
    Please revise the Use of Proceeds here and in the Summary to reflect any plans to repay debt from the proceeds of the offering, such as the April 2024 CLA Amount disclosed on page 4. Please also revise to provide more specific information regarding the amount of proceeds to be used for each potential product identified in the first bullet point, and identify the additional funds that will be needed to develop these products to commercialization, if you are able to obtain the required regulatory approvals.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on pages 12 and 63 of the Amendment No. 6 to reflect the Company’s plans to repay
its debt from the proceeds of the offering, such as the April 2024 CLA Amount and the August 2024 CLA Amount, and provided more information
regarding the amount of proceeds to be used by the Company for each of its identified potential product. In addition, the Company has
revised its disclosure on page 80 of the Amendment No. 6 to identify the additional funds that will be needed to develop these products
to commercialization.

Business, page 75

    3.
    Please clarify the reasons for delays in your trials.

Response: The Company respectfully advises
the Staff that the delays in the Company’s trials are due to the need for proceeds from this offering to execute its development
plan. As a result of the postponement of the Company’s IPO by over a year, from 2023 to 2024, the Company had to adjust its development
timelines, including for its trials.

Intellectual Property, page 103

 4. Please remove any patents that have expired or no longer material to the Company. Please explain the
status designation, “National Phase Entered.” Please also include patent numbers, when available.

Response: In response to the Staff’s
comment, the Company has revised its disclosure on page 103 of the Amendment No. 6 to remove expired and non-material patents. The Company
has also included all available patent application numbers. In addition, the Company respectfully notes that the only patent application
number not available is for the Japanese national phase patent application and advises the Staff that the patent application number will
be available within a few months. Although the patent has been filed, obtaining the application number takes a few months due to the Japanese
patent filing procedure.

Exhibits

 5. Please file the Company’s February 2023 and April 2024 convertible loan agreements as exhibits to the
registration statement.

Response: In response to the Staff’s
comment, the Company has filed the February 2023 and April 2024 convertible loan agreements as exhibits to the Amendment No. 6. In addition,
the Company has filed the August 2024 convertible loan agreement as an exhibit to the Amendment No. 6.

General

 6. We note your references here and elsewhere throughout your disclosure to third party reports and studies
and revised market statistics. When referring to a statistic that is not common knowledge, study, or research article, please provide
a full citation to the source of the information, provide the date of the information, and, at first instance, provide a summary of the
material findings. Specifically, within your discussion within the Market Opportunities section, beginning on page 86, please provide
support for and cite your statements regarding market health and potential growth. In this regard, footnotes may be helpful.

Response: In response to the Staff’s
comment, the Company has revised its disclosures throughout the Amendment No. 6 to provide citations to the sources of the information
when referring to a statistic that is not common knowledge. This includes the disclosure on pages 86 to 90 of the Amendment No. 6, which
contains the Company’s statements regarding market health and potential growth.

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Please contact me at +1 312.364.1633 if
you have any questions or require any additional information in connection with this letter or the Company’s submission of the Amendment
No. 6.

Sincerely,

    /s/ David Huberman

    cc: Tomer Izraeli, Chief Executive Officer

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