SecProbe.io

July 30, 2025
Luis Peña
Chief Executive Officer
Evommune, Inc.
1841 Page Mill Road, Suite 100
Palo Alto, CA 94304
Re:Evommune, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted July 18, 2025
CIK No. 0002044725
Dear Luis Peña:
            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.
Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary
Overview, page 1
1.We note the disclosure that was added with regard to the CIndU Phase 2 trial. Please
revise your disclosure to remove your references to "positive" clinical data and
"positive" topline results. Your disclosure should not imply that your product
candidates will be found to be safe or effective by the FDA or comparable regulatory
bodies and should not state conclusions regarding clinical trial data prior to approval.
Our Clinical Pipeline, page 3
We note your response to prior comment 5. Please revise to provide a more fulsome 2.

July 30, 2025
Page 2
discussion of any development activities conducted with regard to EVO756 for "Other
Indications." To the extent you have conducted limited development for these
indications, please explain why they are sufficiently material to your business to
warrant inclusion in your pipeline table. Alternatively, remove any programs that are
not currently material to your business from your pipeline table. Also, please disclose
why the progress bar for chronic inducible urticaria is colored gray.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Comparison of the Three Months Ended March 31, 2025 and 2024
Operating Expenses
Research and Development , page 97
3.We note your revised disclosure in response to prior comment 9 and reissue in part.
Please elaborate on the increase in "other development programs."
Business
EVO756, Targeting MRGPRX2 for Chronic Inflammatory Diseases, page 111
4.We note your response to prior comment 11. Please revise, where appropriate, to
explain your reasoning for characterizing the clinical and regulatory pathway for
EVO756 as "efficient" given your statement appearing on page 162 claiming that you
do not intend to pursue any accelerated approval pathways for your clinical
candidates. Alternatively, remove this statement from the graphic on page 112.
5.We note your response to prior comment 12 and reissue in part. Please revise to
include a brief discussion of the specific third-party studies you reference
as supporting the rationale for targeting MRGPRX2 for chronic inflammatory
diseases.
Figure 3: EVO756 FricTest Score Improvements and Other Efficacy Metrics, page 114
6.We note the addition of Figure 3 and the "Other Efficacy Metrics." Please clarify
whether these "metrics" were established endpoints in the study. Please also delete the
reference to "efficacy" as your disclosure should not imply that your product
candidates will be found to be safe or effective by the FDA or comparable regulatory
bodies.
Our Mission and Strategy, page 118
7.We note your response to prior comment 13 and reissue. Please remove any other
references to EVO756 or EVO301 being potentially "best-in-class" or "first-in-class"
from your registration statement, as these statements imply that your candidates are
expected to receive FDA approval. We would not object to a general statement
claiming, if true, that it is your goal to develop potential first-in-class and/or best-in-
class drug products without specifically referring to your individual candidates.
            Please contact Tara Harkins at 202-551-3639 or Sasha Parikh at 202-551-3627 if you
have questions regarding comments on the financial statements and related matters. Please
contact Tyler Howes at 202-551-3370 or Chris Edwards at 202-551-6761 with any other
questions.

July 30, 2025
Page 3
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Minkyu Park, Esq.