SecProbe.io

CORRESP
 1
 filename1.htm

 Eleanor
 Osmanoff
 Partner
 eosmanoff@cronelawgroup.com

 VIA
EDGAR

 March
17, 2025

 THE
UNITED STATES SECURITIES

 AND
EXCHANGE COMMISSION

 Division
of Corporation Finance

 Office
of Life Sciences

 Washington,
D.C. 20549

 Attn:
 Doris
 Stacey Gama, Chris Edwards, Christine Torney and Daniel Gordon

 Re:
 Re:
 Curanex Pharmaceuticals Inc
 Amendment
 No. 3 to Registration Statement on Form S-1
 Filed
 February 14, 2025
 File
 No. 333-282686

 Ladies
and Gentlemen:

 On
behalf of our client, Curanex Pharmaceuticals Inc (the "Company"), we are responding to the comments of the staff (the "Staff")
of the Securities and Exchange Commission (the "Commission") contained in the letter dated February 14, 2025 (the "Comment
Letter"), relating to the above-referenced Amendment No. 3 to Registration Statement on Form S-1 (the "Registration Statement").
Concurrently with the submission of this letter, the Company is hereby filing with the Commission Amendment No. 4 to the Registration
Statement ("Amendment #4"). Set forth below are the Company's responses to the
Comment Letter. All references in this response letter include the references to Amendment No. 4. Page
references in the text of this response letter correspond to the page numbers stated in the Comment Letter.

 Notes
to the Financial Statements

 Note
1. Description of Business and Summary of Significant Accounting Policies

 Intangible
Assets, page F-11

 1.
Please revise disclosures to explain why the legal expenses related to filing the provisional patent applications would be
classified as an impairment expense as opposed to being recorded as a research and development expense. Please reference the
accounting literature you relied upon in your response.

 Response :
Please see below the Company's response to this Staff's comment. The Company also amended its disclosures in Amendment #4.

 The
Company has revised its disclosure to clearly state that the legal fees were initially capitalized as an intangible asset on the balance
sheet but were subsequently impaired as an impairment expense in the fourth quarter of 2024. Management originally applied ASC 805-50-30-5
when recognizing the intangible asset as part of the transfer from a related party. This guidance requires that assets transferred between
entities under common control be recorded at their historical carrying amounts.

 However,
management later determined that the intangible asset did not qualify for capitalization, and the immaterial misstatement was corrected
in the fourth quarter of 2024. In addressing the impairment, management referred to ASC 350-30-50-3, which outlines the disclosure requirements
for impairment losses on intangible assets. The following information must be included in the financial statement notes for the period
in which the impairment loss is recognized:

 a.

 A
 description of the impaired intangible asset and the circumstances leading to the impairment

 b.

 The
 impairment loss amount and the method used to determine fair value

 c.

 The
 income statement caption in which the impairment loss is reported

 d.

 If
 applicable, the segment in which the impaired intangible asset is reported under Topic 280.

 Note
5. Related Party Transaction, page F-17

 2.
Please describe the contents of the $100,000 non-cash consideration received in the Duraviva asset purchase agreement and how they were
accounted for the financial statements.

 Response :
The $100,000 in non-cash consideration received in the Duraviva asset purchase agreement consisted of a total of $100,000 paid to the
Company's legal counsel, The Crone Law Group, P.C. ("Crone") in satisfaction of a $100,000 invoice due and payable
by the Company. Of the total $100,000 amount, $75,000 was paid directly to Crone by Duraviva. The remaining $25,000 consisted of
funds held at Crone as a credit balance in favor of the Company's advisor and consultant ("Independent Consultant").
At that time, Independent Consultant was indebted to Duraviva in the amount of $25,000. Duraviva and Independent Consultant mutually
agreed to apply Independent Consultant's $25,000 credit balance at Crone toward the $100,000 invoice owed by the Company,
thereby satisfying Independent Consultant's liability to Duraviva and completing payment of the Company's $100,000
total balance owed to Crone. The total $100,000, consisting of the $75,000 paid directly to Crone on behalf of the Company and
the application of Independent Consultant's credit balance at Crone to the Company's balance due, was recognized in the financial
statements as consideration from Duraviva in the Company's asset acquisition from Duraviva.

 Please
feel free to contact me should you require additional information at (917) 679-5931 or eosmanoff@cronelawgroup.com.

 THE
CRONE LAW GROUP, P.C.

 By:

 /s/
 Eleanor Osmanoff

 Eleanor
 Osmanoff