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    ATTORNEYS
                                            AT LAW

    100
    North Tampa Street, Suite 2700 Tampa,

    FL
    33602-5810 P.O. Box 3391

    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

January
3, 2024

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 Registration Statement on Form S-1

    Filed
    December 14, 2023

    File
    No. 333-275534

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 December 19, 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 an Amendment No. 3 to the Registration Statement on Form S-1 (the “Registration Statement”).

Amendment
1 to Registration Statement on Form S-1

Capitalization,
page 41

    1.
    We
    note here that you present in the actual column 28,609,814 shares of common stock outstanding as of September 30, 2023. However,
    on page F-11 you present 27,097,294 shares of common stock outstanding as of September 30, 2023. Revise the actual outstanding common
    stock share information presented within this table to agree to your unaudited financial statements as of September 30, 2023.

Response:
Please be advised that the Company has revised the number of shares outstanding reflected in the actual column on page 41 of the Registration
Statement to agree to the unaudited financial statements as of September 30, 2023.

    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

January
3, 2024

Page 2 of 3

Dilution,
page 42

    2.
    We
    note your historical net tangible book value per share of $0.04 per share as of September 30, 2023. Please reconcile this with your
    unaudited financial statements on page F-11 which state a historical net tangible book value of $2.1 million as of September 30,
    2023 and 27,097,294 shares of outstanding common stock, which calculates to a historical net tangible book value of $0.08 per share.
    Please note that this methodology also applies to your pro forma and proforma as adjusted net tangible per share
    values.

Response:
Please be advised that the Company has revised the historical net tangible book value and related pro forma and pro forma as adjusted
net tangible book value per share amounts on page 42 to reflect the correct methodology and agree to the amount calculated in
the unaudited financial statements.

    3.
    We
                                            note within Exhibit 23.1 that the auditor’s consent refers to a report dated August
                                            14, 2023 while the report included on page F-1 is dual-dated August 14, 2023, except for
                                            the last paragraph of Note 7, and its related effects to the financial statements, which
                                            is as of December 11, 2023. In your amended filing, please provide an auditor’s consent
                                            that refers to the correct audit report date that is also currently dated and signed by your

    auditors.
    Refer to Item 601(B)(23)(i) of Regulation S-K.

Response:
Please be advised that the Company has obtained an updated auditor’s consent which reflects the updated audit report, is currently
dated, and is signed by the auditors.

January
3, 2024

Page
3 of 3

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