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 March 28, 2025

Udi Gilboa
Executive Chairman
Nasus Pharma Ltd.
Yigal Alon 65
Tel Aviv, Israel 6744317

 Re: Nasus Pharma Ltd.
 Amendment No. 3 to Draft Registration Statement on Form F-1
 Submitted March 21, 2025
 CIK No. 0002029039
Dear Udi Gilboa:

 We have reviewed your amended draft registration statement and have the
following
comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our February 18, 2025 letter.

Amendment No. 3 to Draft Registration Statement on Form F-1
Cover Page

1. We note your graphic appearing after the prospectus cover page. Please
remove the
 pipeline table portion of this graphic and revise the graphic to
disclose that you are a
 development stage company and none of your product candidates have been
approved
 by the Food and Drug Administration. You may present your pipeline table
in the
 Prospectus Summary and/or Business sections, as appropriate.
2. We note your pipeline table in the cover art graphic disclosing your
NS-003, NS-004
 and NS-005 programs. Please revise your Prospectus Summary and Business
 section as appropriate to disclose the molecule for each drug candidate
and the data
 March 28, 2025
Page 2

 produced to date that supports including these programs in your pipeline
table as
 material drug candidates. Alternatively, revise to remove these programs
from your
 pipeline table.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Current Outlook, page 73

3. We note your revised disclosure here that you "may sell fewer than all
of the
 securities offered hereby" appears to conflict with the disclosure on
your cover page
 and elsewhere in your prospectus that you are offering your securities
on a firm-
 commitment basis. Please revise or otherwise advise.
Business
Nasus's Well Differentiated and Diversified Technology Platform - Intranasal
Powder, page
86

4. Please revise your disclosure on page 87 to disclose whether you
produced the nasal
 spray used in the Nasal Cast model. To the extent you did not produce
the spray,
 please revise to disclose why it is appropriate to disclose the results
of this laboratory
 model since it does not present the distribution of your powder sprays
or remove the
 disclosure.
Competitors and Market for NS002, page 102

5. To the extent your comparison of your product candidate to competitors
in the graphic
 at the bottom of page 102 is not based on head-to-head clinical trials,
please remove
 this graphic. Please also remove any similar graphics or claims that
state or imply that
 your products are superior to competitor approved products that are not
based on
 head-to-head clinical trials.
Exhibits

6. We note your removal of the Master Services Agreement with Aptar France
SAS
 from your exhibit index along with the related schedules of work. Please
tell us why
 these agreements are not material contracts pursuant to Item 601(b)(10)
of Regulation
 S-K.
 Please contact Christine Torney at 202-551-3652 or Daniel Gordon at
202-551-3486
if you have questions regarding comments on the financial statements and
related
matters. Please contact Daniel Crawford at 202-551-7767 or Alan Campbell at
202-551-4224
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Eric Victorson, Esq.
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