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    ATTORNEYS
                                            AT LAW

    100
    North Tampa Street, Suite 2700 Tampa,

    FL
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    Tampa,
    FL 33601-3391

    813.229.2300
    TEL

    813.221.4210
    FAX

    www.foley.com

    WRITER’S
    DIRECT LINE 813.225.4122

    ccreely@foley.com

November
13, 2023

Via
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

Washington,
DC 20549

Attention:
Tara Harkins, Lynn Dicker, Jimmy McNamara, and Joe McCann

    Re:
    Telomir
    Pharmaceuticals, Inc.

    Amendment
    No. 1 to Draft Registration Statement on Form S-1

    Submitted
    October 16, 2023

    CIK
    No. 0001971532

Dear
Ms. Harkins, Ms. Dicker, Mr. McNamara, and Mr. McCann:

On
behalf of Telomir Pharmaceuticals, Inc. (the “Company”), we are responding to the comments of the staff of the Division of
Corporation Finance of the United States Securities and Exchange Commission set forth in your letter to Dr. Christopher Chapman, the
Company’s Chief Executive Officer, dated November 1, 2023, relating to the above-referenced filing. Your comments are reproduced
below in italicized bold text, followed by our responses on behalf of the Company. Please be advised that the Company is concurrently
filing via EDGAR a Registration Statement on Form S-1 (the “Registration Statement”).

Amendment
No. 1 to Draft Registration Statement on Form S-1

Business
Summary

Overview,
page 1

    1.
    We
    note your response to comment 1 and re-issue in part. Please revise to explain briefly at first use the term “in situ.”

Response:
Please be advised that the Company has revised the Registration Statement to include the definition of the term “in situ”
in the “Glossary of Certain Scientific Terms” on page iv.

    AUSTIN

    Boston

    CHICAGO

    dallas

    DENVER

    DETROIT

    houston

    JACKSONVILLE

    LOS
    ANGELES

    MADISON

    MEXICO
                                            CITY

    MIAMI

    MILWAUKEE

    NEW
    YORK

    ORLANDO

    SACRAMENTO

    salt
    lake city

    SAN
    DIEGO

    SAN
    FRANCISCO

    SILICON
    VALLEY

    TALLAHASSEE

    TAMPA

    WASHINGTON,
    D.C.

    BRUSSELS

    TOKYO

November
13, 2023

Page
2 of 4

    2.
    We
                                            note your disclosure that you “believe that TELOMIR-1 may effectively serve as a metal
                                            enzyme inhibitor of essential metals such as zinc and copper[]” and that “TELOMIR-1
                                            may protect the stem cells by elongating and stimulating the telomeres to sustain self-renewal
                                            of stem cells.” Please revise your disclosure here and elsewhere to remove any implication
                                            that your product candidates will be safe or effective, as such conclusions are within the
                                            sole authority of the FDA and comparable foreign regulators.

Response:
Please be advised that the Company has revised the language in various places in the Registration Statement to make clear that
conclusions as to safety and efficacy are subject to approval by the FDA and comparable foreign regulators.

Intellectual
Property, page 3

    3.
    We
    note your response to comment 4 and reissue our comment in part. Please revise your disclosure to provide further details about Mr.
    Williams’ scientific background, such as how he “developed extensive knowledge of tobacco alkaloid chemistry in the 1990’s”
    and the context surrounding how Mr. Williams came to work on the “development of techniques for preventing the formation of
    [TSNAs] during the tobacco curing process.” Please also clarify whether the 85 patents or patent applications for which Mr.
    Williams is a named inventor relate to the life sciences industry.

Response:
Please be advised that the Company has revised the Registration Statement to include additional details regarding Mr. Williams’
scientific background. See pages 5 and 62 for the additional information. Further, please be advised that the Company has revised
its disclosure on pages 5 and 62 relating to the patents and patent applications for which Mr. Williams is a named inventor
and that relate to the life sciences industry.

Summary
Risk Factors, page 4

    4.
    We
    note your response to comment 9. Please specify in the seventh bullet point that Dr. Chapman will be working on an as-needed basis.

Response:
Please be advised that the Company has revised the seventh bullet point on page 4 to specify that Dr. Chapman will be working for the
Company on a part-time and as-needed basis. Further, the Company has revised the title of the corresponding risk factor on page 12 to
specify that Dr. Chapman will be working for the Company on a part-time and as-needed basis.

Risks
Related to Our Operations and Financial Condition

Conflicts
of interest may arise between us and MIRALOGX. , page 12

    5.
    We
    note your response to comment 11 and re-issue in part. Please tell us whether any other officers, directors or principal shareholders
    are affiliated with MIRALOGX.

Response:
Please be advised that the Company has revised the Registration Statement to provide that Christos Nicholoudis, our General Counsel and
a member of our board of directors, performs certain consulting work for MIRALOGX on an as-needed basis through his law firm. None of
the other officers, directors, or principal shareholders are affiliated with MIRALOGX.

Risks
Related to Our Intellectual Property

We
may not be able to adequately protect our product candidates or our proprietary technology in the marketplace. , page 29

    6.
    We
                                            note your response to comment 5 and your revised disclosure on page 30 noting that you do
                                            not own the rights to the intellectual property and technology that will be used to commercially
                                            develop TELOMIR-1 and that MIRALOGX holds those patent rights through a “pending patent
                                            application.” Please revise your risk factor disclosure to explain the risks associated
                                            with not having patent coverage for the work you are conducting. Please also clarify here
                                            and elsewhere, as appropriate, that MIRALOGX has filed a nonprovisional patent application.

Response:
Please be advised that the Company has revised the Registration Statement to include a risk factor associated with not having patent
coverage for the work the Company is conducting. The Company has further revised the Registration Statement to clarify that MIRALOGX
has filed a nonprovisional patent application.

November
                                            13, 2023

Page
3 of 4

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 41

    7.
    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 including any stock options
                                            issued 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:
For the information of the Staff, the Company has not to date granted any stock options or other equity compensation, and
its historical financial statements do not include any stock compensation expense.

Business

Overview,
page 46

    8.
    We
    note your response to prior comment 14 and your revised disclosure regarding the results of the study comparing the complexing abilities
    of TELOMIR-1 and doxycycline. Please revise your disclosure further to explain why TELOMIR-1 was compared with doxycycline in this
    regard.

Response:
Please be advised that the Company has revised the Registration Statement to further explain why TELOMIR-1 was compared to doxycycline.

    9.
    We
    note your response to prior comment 15 and your revised disclosure regarding the results of your studies comparing the anti-cancer
    activities of TELOMIR-1 versus rapamycin. Please revise your disclosure further to explain why TELOMIR-1 was compared with rapamycin
    in this regard.

Response:
Please be advised that the Company has revised the Registration Statement to further explain why TELOMIR-1 was compared to rapamycin.

In
silico Affinity Studies, page 52

    10.
    We
    note your disclosure on page 52 that “[p]re-clinical studies demonstrate that TELOMIR-1 . . . turn[s] off the underlying cause
    of cancer development and growth.” Please revise your disclosure here to remove the implication that your product is safe or
    effective as such conclusions are within the sole authority of the FDA and comparable foreign regulators..

Response:
Please be advised that the Company has revised the Registration Statement to make clear that conclusions as to safety and efficacy
are within the sole authority of the FDA and comparable foreign regulators.

    11.
    We
    note your response to prior comment 18. We reissue our comment in part. Please revise your disclosure to clarify whether the pre-clinical
    studies described in this section were conducted with the assistance of any third parties.

Response:
Please be advised that the Company has revised the Registration Statement to clarify that all pre-clinical studies were conducted with
the assistance of third parties.

General

    12.
    Please
    ensure the writing is legible in the visual depictions throughout your draft registration statement. For example only, certain text
    on pages 48-50 is not legible.

Response:
Please be advised that the Company has revised the Registration Statement to replace the illegible visual depictions and graphics with
images and tables that are clearly legible.

November
                                            13, 2023

Page
4 of 4

Should
you have any additional questions, please do not hesitate to contact the undersigned at 813.225.4122.

    Best
    regards,

    /s/
    Curt P. Creely

    Curt
    P. Creely