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CORRESP
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 Wyrick Robbins Yates & Ponton LLP
 ATTORNEYS AT LAW
 4101 Lake Boone Trail, Suite 300, Raleigh, NC 27607
 PO Drawer 17803, Raleigh, NC 27619
 P: 919.781.4000 F: 919.781.4865 www.wyrick.com

 June 27, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Gary Newberry

 Kevin Vaughn

 Joshua Gorsky

 Joe McCann

 Division of Corporation Finance

 Office of Life Sciences

 Re: Adaptin Bio, Inc.

 Registration Statement on Form S-1

 File No. 333-287338

 Filed May 16, 2025

 Gentlemen:

 We write this letter on behalf of our
client Adaptin Bio, Inc. (the "Company") in response to the comments of the staff (the "Staff") of the U.S. Securities
and Exchange Commission (the "Commission") with respect to the above-captioned filing, as set forth in the Staff's letter
dated June 13, 2025 (the "Comment Letter"). The relevant text of the Comment Letter has been reproduced herein in bold with
our response below the numbered comments. Disclosure changes made in response to the Staff's comments have been made in Amendment
No. 1 to the Registration Statement on Form S-1 (the "Amendment"), which is being filed with the Commission contemporaneously
with the submission of this letter.

 Registration Statement on Form S-1

 Cautionary Note…., page iii

 1. Please revise to remove the reference to Section 27A and Section 21E. We note that these safe harbor provisions do not apply to
initial public offerings.

 The Company respectfully acknowledges the Staff's comment and
has removed the reference to Section 27A and Section 21E under the heading "Cautionary Note Regarding Forward-Looking Statements"
on page iii of the Amendment.

 Division of Corporation Finance, Office of Life Sciences

 June 27, 2025

 Prospectus Summary, page 1

 2. We note that disclosures here, and elsewhere in the prospectus, contain performance claims as well as statements indicating or
suggesting that your product candidate is safe and/or effective. Because your product candidate is pre-clinical and because safety and
efficacy determinations are in the exclusive purview of FDA and other similar foreign regulators, please revise or remove these statements.
For example only, we note the following statements:

 ● On
page 1, BRiTE "redirects patients' own T cells to recognize and destroy tumor cells."

 ● On
page 2, your technology "enable drugs to cross barriers and target tissues, including the brain[.]"

 ● On
page 39, your product candidate "successfully activates human T cells against EGFRvIII expressing target cells . . . resulting in
the secretion of Th-1-associated cytokines and tumor-killing."

 ● On
page 39, your product candidate is "similarly effective[.]"

 ● On
page 39, your product candidate "represents a critical conceptual advance in safety[.]"

 ● On
page 42, you have "demonstrated an effective ‘antidote[.]'"

 ● On
page 42 your technology has an "acceptable safety profile."

 ● On
page 42, your preclinical studies demonstrate a "safe, highly effective therapeutic option[.]"

 ● On
page 49, your product candidate "is able to eliminate malignant glioma tumors[.]"

 The Company respectfully acknowledges the Staff's comment
and has revised the disclosures noted by the Staff on pages 1, 2, 39, 42 and 49 of the Amendment accordingly. The Company also
has revised similar disclosures on page 35 of the Amendment and page F-8 of Adaptin Bio Operating Corporation's financial statements
for the years ended December 31, 2024 and 2023 in the Amendment (previously "BRiTE is a translatable method to specifically target
malignant glioma using a tumor-specific, fully human bispecific antibody that redirects patients' own T cells to recognize and destroy
tumor cells") and page 36 of the Amendment (previously "Because our proprietary technology enables drugs to cross barriers
and target tissues, including the brain, we believe it has numerous potential applications in areas of unmet medical need").

 Strategy, page 2

 3. We note your disclosure that "[d]rawing upon [y]our experience in commercializing specialty pharmaceutical products, [you]
aim to build a specialized yet efficient infrastructure that will support the entire commercialization continuum[.]" Please provide
the basis for your claim that you have experience "commercializing specialty pharmaceutical products." In this regard, we note
your disclosure on page 8 that you have generated no revenue from commercial sales and your disclosure on page 18 that you "do not
have experience in selling or marketing[.]"

 The Company respectfully acknowledges the Staff's comment and
has updated the disclosure on page 2 of the Amendment to clarify that individual members of the Company's leadership team (as
opposed to the Company itself) have experience commercializing specialty pharmaceutical products.

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 Division of Corporation Finance, Office of Life Sciences

 June 27, 2025

 Summary Risk Factors, page 3

 4. Please include in your summary risk factors that you identified material weaknesses in your internal control over financial reporting
that were present as of December 31, 2024 and continued to exist as of March 31, 2025.

 The Company respectfully acknowledges the Staff's
comment and has revised its summary risk factors on page 4 of the Amendment accordingly.

 Anti-takeover provisions in our charter documents and under Delaware
law could make...page 30

 5. We note your disclosure that your Federal Forum Provision and your "exclusive forum provision" may "limit a stockholder's
ability to bring a claim in a judicial forum of their choosing[.]" Please revise your disclosure to state that such provisions may
also make it more costly for stockholders to bring a claim against you.

 The Company respectfully acknowledges the Staff's comment
and has revised the risk factor regarding anti-takeover provisions in the Company's charter on pages 30 and 31 of the Amendment
accordingly.

 Business of the Company

 Our Product Pipeline, page 39

 6. We note your inclusion of Figures 1-4 in the registration statement. Please revise each of these graphics to ensure that all text
is legible.

 The Company respectfully acknowledges the Staff's comment
and has revised each of Figures 1-4 on pages 39, 40 and 41 of the Amendment such that all text is legible in the graphics.

 7. Please revise your disclosure to provide further details about the preclinical studies described in this section, including the
structure of the studies, who conducted them and when they did so.

 The Company respectfully acknowledges the Staff's comment
and has updated the disclosure on page 39 of the Amendment accordingly.

 APTN-101 Clinical Studies, page 42

 8. Please revise your disclosure here to clarify the clinical endpoints of the proposed Phase 1 study and whether it will be powered
for statistical significance.

 The Company respectfully acknowledges the Staff's comment
and has updated the disclosure on page 42 of the Amendment accordingly.

 9. Please revise your disclosure to clarify if the Phase 1 clinical trial has begun. If the clinical trial has not yet begun, please
explain why. In this regard, we note your reference on page 36, and elsewhere in the prospectus, to the "FDA's acceptance in May
2023 of the IND for APTN-101 for the treatment of glioblastoma[.]"

 The Company respectfully acknowledges the Staff's comment
and has updated the disclosure on page 42 of the Amendment to note that the Phase I study is expected to initiate in the second half
of 2025.

 3

 Division of Corporation Finance, Office of Life Sciences

 June 27, 2025

 10. Please define the term "PK" in the first instance.

 The Company respectfully acknowledges the Staff's comment
and has defined the term "PK" (pharmacokinetics) in its first instance on page 42 of the Amendment.

 License Agreement

 Patent License Agreement with Duke University, page
43

 11. We note your disclosure that, pursuant to the SRA, Duke University agreed to perform research exploring the administration methods
of your Bri[T]E Platform for a fixed fee. Please disclose the fixed fee referenced here.

 The Company respectfully acknowledges the Staff's
comment and has updated the disclosure on page 43 of the Amendment to disclose the fixed fee.

 12. We note your disclosure that you must pay Duke University "low to mid-double-digit percentages of any sublicensing fees as
set forth in the Duke License." Please revise to specify the range of percentages of sublicensing fees to be within ten percentage
points (i.e., a double-digit percentage in the teens).

 The Company respectfully acknowledges the Staff's comment
and has updated the disclosures accordingly on pages 43 and 56 of the Amendment and page F-18 of Adaptin Bio Operating Corporation's
financial statements for the years ended December 31, 2024 and 2023 included in the Amendment.

 13. Please revise your disclosure to state the amount that has been paid under the Duke License to date.

 The Company respectfully acknowledges the Staff's comment
and has updated the disclosure on page 43 of the Amendment to disclose the amount that has been paid under the Duke License to date.

 Management's Discussion and Analysis of Financial
Condition and results of Operations, page 51

 14. Revise your discussions of research and development expenses to provide a breakdown by nature or type of costs for each period
presented. As part of your breakdown, separately quantify your external clinical trial costs as well as in-process research and development
charges.

 The Company respectfully acknowledges the Staff's comment
and has updated the disclosures on pages 52 and 53 of the Amendment accordingly.

 4

 Division of Corporation Finance, Office of Life Sciences

 June 27, 2025

 Committee of the Board of Directors, page 62

 15. We note your reference to a Compensation Committee on page 64. Accordingly, please disclose the composition of the Compensation
Committee here.

 The Company respectfully acknowledges the Staff's comment
and has revised its disclosure on page 64 of the Amendment to remove reference to the compensation committee, as the Company's
Board of Directors (the "Board") does not currently have a compensation committee. The Company will disclose the composition
of the Board's compensation committee, if and when one is established, in future filings where responsive.

 Compensation of Directors and Executive Officers,
page 63

 16. We note your disclosure that your board of directors intends to grant each Independent Director equity awards equal to 0.20% of
the Company's fully diluted shares outstanding at the time of grant. Please provide further details about these equity awards, including,
but not limited to, when these equity awards are scheduled to be granted and whether they are tied to specific milestones or achievements.

 The Company respectfully acknowledges the Staff's comment
and has revised its disclosure on page 63 of the Amendment to provide further details about the equity awards to be granted to certain
Board members, including the nature of the equity awards and their vesting schedule.

 Equity Compensation Plan Information, page 70

 17. We note your reference to the "2025 Equity Incentive Plan" on page 70. Where appropriate, please provide a description
of the 2025 Equity Incentive Plan within the prospectus.

 The Company respectfully acknowledges the Staff's comment
and has revised its disclosure on pages 70-77 of the Amendment to include a description of the 2025 Equity Incentive Plan under the
heading "Equity Compensation Plan Information."

 Description of Capital Stock

 Warrants and Placement Agent Warrants, page 77

 18. Please explain here, and elsewhere as appropriate, how the Pre-Merger Warrants have an exercise price of "either $3.30 per
share or $4.40 per share." Further, please revise your disclosure in this section to state when each of the outstanding warrants
will expire.

 The Company respectfully acknowledges the Staff's comment.
Prior to the merger (the "Merger") by and among Unite Acquisition 1 Corp. ("Unite Acquisition"), its wholly-owned
subsidiary, Adaptin Acquisition Co., a Delaware Corporation formed in the State of Delaware on January 30, 2025 ("Merger Sub"),
and Adaptin Bio Operating Corporation (formerly Adaptin Bio, Inc. and referred to herein as "Private Adaptin"), Private Adaptin
raised bridge financing through the offer and sale of $500,000 principal amount of its 10% Secured Promissory Notes (the "2023 Bridge
Notes"). Private Adaptin agreed to issue common stock warrants (the "2023 Bridge Note Warrants") to the purchasers of
the 2023 Bridge Notes. The 2023 Bridge Note Warrants give the holders the right to purchase an aggregate of up to 56,815 shares of Common
Stock at an exercise price of $4.40 per share. In December 2024, the 2023 Bridge Notes were cancelled and exchanged for $500,000 principal
amount of Private Adaptin's 10% Secured Convertible Promissory Notes (the "Exchange Notes"). In connection with
this note exchange, the holders of the 2023 Bridge Notes were issued warrants (the "Exchange Warrants") to purchase an aggregate
of up to 75,755 shares of our Common Stock at an exercise price of $3.30 per share. The 2023 Bridge Note Warrants and the Exchange Warrants
must be exercised on or prior to the close of business on February 11, 2030, which is the fifth anniversary of the initial closing of
the Private Placement. We have revised the disclosures on pages 6, 49, and 84 of the Amendment to reflect the above.

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 Division of Corporation Finance, Office of Life Sciences

 June 27, 2025

 Exhibits

 19. Please remove all references to "information incorporated by reference" and attach all of your relevant exhibits to this
registration statement or provide us with your analysis regarding your eligibility to incorporate by reference on Form S-1. In this regard,
we note that companies that were either shell companies or blank check companies during the past three years are ineligible to incorporate
by reference on Form S-1. Please refer to General Instruction VII.D of Form S-1 for guidance.

 The Company respectfully acknowledges the Staff's comment
and has revised its disclosures on pages II-3 and II-4 of the Amendment to attach all of its relevant exhibits to the Amendment.

 General

 20. Please provide us with a detailed analysis regarding your basis for determining that this transaction is appropriately characterized
as a secondary offering that is eligible to be made under Rule 415(a)(1)(i) rather than a primary offering. Please refer to Securities
Act Rules Compliance & Disclosure Interpretations Question 612.09.

 For the reasons set forth below, the Company respectfully submits
to the Staff that the proposed resale of shares of the Company's common stock (the "Common Stock") by the Selling Stockholders
named in the prospectus which forms a part of the Registration Statement (the "Prospectus") is not a primary offering and
is appropriately characterized as a secondary offering that is eligible to be made under Rule 415(a)(1)(i) of Regulation C under the Securities
Act of 1933, as amended (the "Securities Act").

 Rule 415(a)(1)(i) provides that securities may be registered
for an offering to be made on a continuous or delayed basis in the future, provided that the registration statement pertains only to securities
"which are to be offered or sold solely by or on behalf of a person or persons other than the registrant, a subsidiary of the registrant
or a person of which the registrant is a subsidiary." Thus, Rule 415(a)(1)(i) permits an issuer to register securities to be sold
on a delayed or continuous basis by the Selling Stockholders as contemplated in the Registration Statement in a secondary offering.

 In Securities Act Rules - Compliance & Disclosure Interpretation
("C&DI") 612.09, the Staff sets forth factors