SecProbe.io

CORRESP
 1
 filename1.htm

 Acurx Pharmaceuticals, Inc.

 259 Liberty Avenue

 Staten Island, NY 10305

 January 2, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Alan Campbell

 Re:
 Acurx Pharmaceuticals, Inc.

 Registration Statement on Form S-3, as amended

 Filed July 9, 2025

 File No. 333-288595 (the "Registration
Statement")

 Acceleration Request

 Ladies and Gentlemen:

 In accordance with Rule 461 of Regulation
C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the "Registrant") hereby respectfully
requests that the Securities and Exchange Commission accelerate the effective date of the above-referenced Registration Statement to January 6,
2026, at 4:00 p.m., Eastern Time, or as soon as thereafter practicable.

 The cooperation of the staff in meeting the timetable
described above is very much appreciated.

 Please contact Jeffrey D. Cohan of Mintz, Levin,
Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6710 with any questions regarding this request.

 Very truly yours,

 Acurx Pharmaceuticals, Inc.

 /s/ David P. Luci

 David P. Luci

 President and Chief Executive Officer

 cc:
 Mintz, Levin.
 Cohn. Ferris. Glovsky and Popeo. P.C

 Ivan K. Blumenthal, Esq.

 Jeffrey D. Cohan, Esq.

CORRESP
 1
 filename1.htm

 Acurx Pharmaceuticals, Inc.

 259 Liberty Avenue
Staten Island, New York 10305

 July 21, 2025

VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Alan Campbell

 Re:
 Acurx Pharmaceuticals, Inc.

 Registration Statement on Form S-1

 File No. 333-288667

 Request for Acceleration

 Ladies and Gentlemen:

 Pursuant to Rule 461 of Regulation
C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the "Registrant") hereby requests
acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-288667), so that it may become effective at
4:01 p.m. (Washington, D.C. time) on July 23, 2025, or as soon thereafter as practicable.

 Please call Ivan K. Blumenthal
or Jeffrey D. Cohan of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 or (212) 692-6710
with any comments or questions regarding this matter.

 Very truly yours,

 Acurx Pharmaceuticals, Inc.

 By:
 /s/ David P. Luci

 Name: David P. Luci

 Title: President and Chief Executive Officer

 cc:
 Acurx Pharmaceuticals, Inc.

 David P. Luci
 Robert G. Shawah

 Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

 Ivan K. Blumenthal, Esq.
 Jeffrey D. Cohan, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 21, 2025

David Luci
President and Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, NY 10305

 Re: Acurx Pharmaceuticals, Inc.
 Registration Statement on Form S-1
 Filed July 15, 2025
 File No. 333-288667
Dear David Luci:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Alan Campbell at 202-551-4224 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Jeffrey D. Cohan
</TEXT>
</DOCUMENT>

July 14, 2025
David Luci
President and Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, NY 10305
Re:Acurx Pharmaceuticals, Inc.
Registration Statement on Form S-3
Filed July 9, 2025
File No. 333-288595
Dear David Luci:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Alan Campbell at 202-551-4224 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Jeffrey D. Cohan

CORRESP
 1
 filename1.htm

 Acurx Pharmaceuticals, Inc.

 259 Liberty Avenue
Staten Island, New York 10305

 May 27, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Jessica Dickerson

 Re:

 Acurx Pharmaceuticals, Inc.

 Registration Statement on Form S-1

 File No. 333-287478

 Request for Acceleration

 Ladies and Gentlemen:

 Pursuant to Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the "Registrant")
hereby requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-287478), so that
it may become effective at 4:01 p.m. (Washington, D.C. time) on May 29, 2025, or as soon thereafter as practicable.

 Please call Ivan K. Blumenthal
or Jeffrey D. Cohan of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 or (212) 692-6710
with any comments or questions regarding this matter.

 Very truly yours,

 Acurx Pharmaceuticals, Inc.

 By:
 /s/ David P. Luci

 Name:
 David P. Luci

 Title:
 President and Chief Executive Officer

 cc:
 Acurx Pharmaceuticals, Inc.

 David P. Luci
 Robert G. Shawah

 Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

 Ivan K. Blumenthal, Esq.
 Jeffrey D. Cohan, Esq.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 27, 2025

David Luci
Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, NY 10305

 Re: Acurx Pharmaceuticals, Inc.
 Registration Statement on Form S-1
 Filed May 21, 2025
 File No. 333-287478
Dear David Luci:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Jessica Dickerson at 202-551-8013 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Ivan Blumenthal, Esq.
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 10, 2025

David P. Luci
President and Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, NY 10305

 Re: Acurx Pharmaceuticals, Inc.
 Registration Statement on Form S-1
 Filed April 4, 2025
 File No. 333-286384
Dear David P. Luci:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Jessica Dickerson at 202-551-8013 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Ivan K. Blumenthal, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Acurx Pharmaceuticals, Inc.

 259 Liberty Avenue
Staten Island, New York 10305

 April 10, 2025

VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Jessica Dickerson

 Re:
 Acurx Pharmaceuticals, Inc.

 Registration Statement on Form S-1

 File No. 333-286384

 Request for Acceleration

 Ladies and Gentlemen:

 Pursuant to Rule 461 of Regulation
C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the "Registrant") hereby requests
acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-286384), so that it may become effective at
4:01 p.m. (Washington, D.C. time) on April 14, 2025, or as soon thereafter as practicable.

 Please call Ivan K. Blumenthal
or Jeffrey D. Cohan of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 or (212) 692-6710
with any comments or questions regarding this matter.

 Very truly yours,

 Acurx Pharmaceuticals, Inc.

 By:
 /s/ David P. Luci

 Name:
 David P. Luci

 Title:
 President and Chief Executive Officer

 cc:
 Acurx Pharmaceuticals, Inc.

 David P. Luci

 Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

 Ivan K. Blumenthal, Esq.

 Jeffrey D. Cohan, Esq.

February 4, 2025
David P. Luci
President, Chief Executive Officer and Director
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, NY 10305
Re:Acurx Pharmaceuticals, Inc.
Registration Statement on Form S-1
Filed January 31, 2025
File No. 333-284627
Dear David P. Luci:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Daniel Crawford at 202-551-7767 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Ivan Blumenthal, Esq.

CORRESP
1
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Acurx Pharmaceuticals, Inc.

259 Liberty Avenue

Staten Island, New York 10305

February 4, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Daniel Crawford

    Re:
    Acurx Pharmaceuticals, Inc.

Registration Statement on Form S-1

File No. 333-284627

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation
C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the “Registrant”) hereby requests
acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-284627), so that it may become effective at
4:01 p.m. (Washington, D.C. time) on February 6, 2025, or as soon thereafter as practicable.

Please call Ivan K. Blumenthal
or Jeffrey D. Cohan of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 or (212) 692
6710 with any comments or questions regarding this matter.

    Very truly yours,

    Acurx Pharmaceuticals, Inc.

    By:
     /s/ David P. Luci

    Name: David P. Luci

    Title:   President and Chief Executive Officer

    cc:
    Acurx Pharmaceuticals, Inc.

    David P. Luci

    Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

    Ivan K. Blumenthal, Esq.

    Jeffrey D. Cohan, Esq.

CORRESP
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Acurx Pharmaceuticals, Inc.

259 Liberty Avenue

Staten Island, New York 10305

July 6, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Alan Campbell

    Re:
    Acurx Pharmaceuticals, Inc.

    Registration Statement on Form S-1

    File No. 333-273015

    Request for Acceleration

Dear Mr. Campbell:

Pursuant to Rule 461 of Regulation
C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the “Registrant”) hereby requests
acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-273015), so that it may become effective at
5:00 p.m. (Washington, D.C. time) on July 10, 2023, or as soon thereafter as practicable.

Please call Ivan K. Blumenthal
or Jeffrey D. Cohan of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 or (212) 692
6710 with any comments or questions regarding this matter.

    Very truly yours,

    Acurx Pharmaceuticals, Inc.

    By:
    /s/ David P. Luci

    Name: David P. Luci

    Title:   President and Chief Executive Officer

    cc:
    Acurx Pharmaceuticals, Inc.

    David P. Luci

    Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

    Ivan K. Blumenthal, Esq.

    Jeffrey D. Cohan, Esq.

United States securities and exchange commission logo
July 5, 2023
David Luci
President and Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, New York 10305
Re:Acurx Pharmaceuticals, Inc.
Registration Statement on Form S-1
Filed June 29, 2023
File No. 333-273015
Dear David Luci:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Alan Campbell at 202-551-4224 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Jeffrey D. Cohan

CORRESP
1
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Acurx Pharmaceuticals, Inc.

259 Liberty Avenue

Staten Island, New York 10305

September 20, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Margaret Schwartz

    Re:
    Acurx Pharmaceuticals, Inc.

    Registration Statement on Form S-1

    File No. 333-267412

    Request for Acceleration

Dear Ms. Schwartz:

Pursuant to Rule 461 of Regulation
C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the “Registrant”) hereby requests
acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-267412), so that it may become effective at
5:00 p.m. (Washington, D.C. time) on September 22, 2022, or as soon thereafter as practicable.

Please call Ivan K. Blumenthal
of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 with any comments or questions regarding
this matter.

Very truly yours,

Acurx Pharmaceuticals, Inc.

By:
/s/ David P. Luci

Name:
David P. Luci

Title:
President and Chief Executive Officer

    cc:
    Acurx Pharmaceuticals, Inc.

        David P. Luci

    Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

    Ivan K. Blumenthal, Esq.

United States securities and exchange commission logo
September 19, 2022
David P. Luci
President and Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, New York 10305
Re:Acurx Pharmaceuticals, Inc.
Registration Statement on Form S-1
Filed September 14, 2022
File No. 333-267412
Dear Mr. Luci:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Margaret Schwartz at 202-551-7153 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ivan Blumenthal, Esq.

CORRESP
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ACURX PHARMACEUTICALS, INC.

259 Liberty Avenue

Staten Island, New York 10305

July 7, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attention: Christine Westbrook

 Re: Acurx Pharmaceuticals,
                                            Inc.

    Registration Statement on Form S-3

    Filed July 1, 2022

    File No. 333-265956 (the “Registration Statement”)

    Acceleration Request

Dear Ms. Westbrook:

In accordance with Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, Inc. (the “Registrant”) hereby
respectfully requests that the Securities and Exchange Commission accelerate the effective date of the above-referenced Registration Statement
to Monday, July 11, 2022, at 4:01 p.m., Eastern Time, or as soon as thereafter practicable.

The cooperation of the staff
in meeting the timetable described above is very much appreciated.

Please contact Ivan Blumenthal,
of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 with any questions regarding this
request.

    Very truly yours,

Acurx Pharmaceuticals, Inc.

    By:
    /s/ David P. Luci

    Name:
    David P. Luci

    Title:
    President and Chief Executive Officer

cc:       Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Ivan
K. Blumenthal, Esq.

United States securities and exchange commission logo
July 7, 2022
David P. Luci
Chief Executive Officer
Acurx Pharmaceuticals, Inc.
259 Liberty Avenue
Staten Island, NY 10305
Re:Acurx Pharmaceuticals, Inc.
Registration Statement on Form S-3
Filed July 1, 2022
File No. 333-265956
Dear Mr. Luci:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Christine Westbrook at 202-551-5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ivan Blumenthal, Esq.

CORRESP
1
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June 22, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Acurx Pharmaceuticals, LLC

Registration
Statement on Form S-1, as amended

File
No. 333-256516

Request
for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, as amended (the “Securities Act”), Alexander Capital, L.P., as the representative
of the several underwriters, hereby joins in the request of Acurx Pharmaceuticals, LLC for acceleration of the effective date of the above-referenced
registration statement on Form S-1, as amended (the “Registration Statement”), so that it becomes effective as
of 5:00 p.m. Eastern Time on Thursday, June 24, 2021, or as soon thereafter as possible.

Pursuant to Rule 460 of the General Rules and
Regulations of the Securities Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated
to be invited to participate in the distribution of the securities, as many copies of the proposed form of preliminary prospectus as appears
to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned has and will comply, and it has
been informed or will be informed by any participating dealers that they have complied or will comply, with the requirements of Rule 15c2-8
under the Securities Exchange Act of 1934, as amended.

[Signature Page to Follow]

    Very truly yours,

    ALEXANDER CAPITAL, L.P.

    As Representative of the Several Underwriters

    Named in the Underwriting Agreement

    By:
    /s/ Jonathan Gazdak

    Name: 	Jonathan Gazdak

    Title:    Managing Director

[Signature Page to Underwriters’
Acceleration Request]

CORRESP
1
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ACURX PHARMACEUTICALS, LLC

259 Liberty Avenue

Staten Island, NY 10305

June 22, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jane Park

    Re:

    Acurx Pharmaceuticals, LLC

    Registration Statement on Form S-1

    File No. 333-256516

    Request for Acceleration

Dear Ms. Park:

Pursuant to Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, Acurx Pharmaceuticals, LLC (the “Registrant”) hereby
requests acceleration of the effective date of its Registration Statement on Form S-1 (File No. 333-256516), so that it may become effective
at 5:00 p.m. (Washington, D.C. time) on Thursday, June 24, 2021, or as soon thereafter as practicable.

Please call Ivan Blumenthal,
of Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C., counsel to the Registrant, at (212) 692-6784 with any comments or questions regarding
this matter.

    Very truly yours,

Acurx Pharmaceuticals, LLC

    By:
    /s/ David Luci

    Name:
    David Luci

    Title:
    President and Chief Executive Officer

 cc: Acurx Pharmaceuticals, LLC

David Luci

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Ivan K. Blumenthal, Esq.

CORRESP
1
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    Chrysler
    Center

    666 Third
    Avenue

    New York,
    NY 10017

    212 935
    3000

    mintz.com

May 26, 2021

CONFIDENTIAL – VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Consumer Products

100 F Street, N.E.

Washington, D.C. 20549

Attention: Tracie Mariner

Brian Cascio

Jane Park

Celeste Murphy

 Re: Acurx Pharmaceuticals, LLC

Registration Statement on Form S-1

Submitted May 10, 2021

CIK No. 0001736243

Ladies and Gentlemen:

This letter sets forth the
response of Acurx Pharmaceuticals, LLC (the “Company”) to the comment letter, dated May 21, 2021, of the staff
of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
with respect to the Company’s Amendment No. 1 to the Draft Registration Statement on Form S-1 confidentially submitted
to the Commission on May 10, 2021 for confidential non-public review pursuant to the Jumpstart Our Business Startups Act, as amended.
Concurrently, the Company is filing publicly a Registration Statement on Form S-1 (the “Registration Statement”).
Defined terms used but not otherwise defined herein have the meanings ascribed to such terms in the Registration Statement.

In order to facilitate your
review, we have repeated the comment in its entirety in italicized text and followed by the Company’s response.

 1. We refer to the GLSynthesis Inc. Asset Purchase Agreement filed as Exhibit 10.11 to your registration
statement. We note that certain identified information has been redacted in this exhibit as noted in the exhibit index. Please revise
the first page of the exhibit to include a statement that certain identified information has been excluded from the exhibit because
it is both not material and is the type that you treat as private or confidential. Please also include brackets indicating where the information
is omitted from the filed version of the exhibit. Refer to Item 601(b) of Regulation S-K.

Response:
The Company respectfully acknowledges the Staff's comment and has revised Exhibit 10.11 to the Registration Statement to note that
certain identified information has been redacted as noted in the exhibit index.

If you have any questions
or comments in connection with this letter or the Registration Statement, please contact the undersigned by phone at (212) 692-6784 or
via e-mail at ikblumenthal@mintz.com.

    Very truly yours,

    /s/ Ivan K. Blumenthal

    Ivan K. Blumenthal

cc:          David P.
Luci, Chief Executive Officer (Acurx Pharmaceuticals, LLC)

Boston       London       Los
Angeles       New York       San Diego       San
Francisco      Washington

MINTZ,
LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

United States securities and exchange commission logo
May 21, 2021
David Luci
Chief Executive Officer
Acurx Pharmaceuticals, LLC
259 Liberty Avenue
Staten Island, NY 10305
Re:Acurx Pharmaceuticals, LLC
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted May 10, 2021
CIK No. 0001736243
Dear Mr. Luci:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            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 our comments apply 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 these comments 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 submitted May 10, 2021
Exhibits
1.We refer to the GLSynthesis Inc. Asset Purchase Agreement filed as Exhibit 10.11 to your
registration statement. We note that certain identified information has been redacted in
this exhibit as noted in the exhibit index.  Please revise the first page of the exhibit to
include a statement that certain identified information has been excluded from the exhibit
because it is both not material and is the type that you treat as private or confidential.
Please also include brackets indicating where the information is omitted from the filed
version of the exhibit.  Refer to Item 601(b) of Regulation S-K.

 FirstName LastNameDavid Luci
 Comapany NameAcurx Pharmaceuticals, LLC
 May 21, 2021 Page 2
 FirstName LastName
David Luci
Acurx Pharmaceuticals, LLC
May 21, 2021
Page 2
            You may contact Tracie Mariner at 202-551-3744 or Brian Cascio at 202-551-3676 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ivan Blumenthal, Esq.

United States securities and exchange commission logo
April 30, 2021
David Luci
Chief Executive Officer
Acurx Pharmaceuticals, LLC
259 Liberty Avenue
Staten Island, NY 10305
Re:Acurx Pharmaceuticals, LLC
Draft Registration Statement on Form S-1
Submitted April 5, 2021
CIK No. 0001736243
Dear Mr. Luci:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            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 our comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 submitted April 5, 2021
Our Technology, page 1
1.We note your statement on page 1 and elsewhere that ibezapolstat is a first-in-class
product candidate.  The term “first-in-class” suggests that the product candidate is
effective and likely to be approved as a new class of antibiotic candidates.  Given the early
stage of development of ibezapolstat, it is not appropriate to suggest that this product is
likely to be effective or receive regulatory approval.  Please delete these references
throughout your registration statement.  If your use of the term was intended to convey
your belief that the product is based on a novel technology or approach, you may discuss
how your technology differs from technology used by competitors.

 FirstName LastNameDavid Luci
 Comapany NameAcurx Pharmaceuticals, LLC
 April 30, 2021 Page 2
 FirstName LastName
David Luci
Acurx Pharmaceuticals, LLC
April 30, 2021
Page 2
2.Please revise your disclosure in the Summary and the Business section to provide clear
descriptions of the Clinical Cure, primary and secondary endpoints for your Phase 1 and
Phase 2a trials, as applicable.
3.We note your disclosure on page 2 that your second antibiotic candidate is currently in the
lead-optimization stage.  Please revise your disclosure in the Summary to clarify that this
candidate is also in the preclinical stage of development.
4.You disclose on page 2 and elsewhere in the prospectus that you terminated your Phase 2a
clinical trial early based upon the recommendation of your Scientific Advisory Board.
Please revise your disclosure to include the specific reasons and analysis that your
scientific and medical advisors provided in support of its recommendation, including the
references on pages 2 and 64.  If material, please file the written consent of the scientific
experts as an exhibit to the registration statement or explain to us why you do not believe
you are required to do so.  Refer to Rule 436 of Regulation S-K.
Effects of the Coronavirus on Our Business, page 6
5.Please expand your disclosure in the Summary regarding the impact the COVID-19
pandemic on your business to include the Paycheck Protection Program loan you received
in 2020 under the CARES Act. We note your disclosure on page F-10.
We contract with third parties for the manufacture of our product candidates..., page 22
6.We note your risk factor disclosure that certain of your materials are only available from a
single-source supplier.  Please expand your disclosure here to discuss your sources, the
availability of raw materials and the names of any principal suppliers.  See Item
101(h)(4)(v) of Regulation S-K.
Use of Proceeds, page 39
7.To the extent known, please revise to identify the specific product candidates for which
you intend to use the proceeds of the offering.  Please also disclose the approximate
amount of proceeds you intend to allocate toward each of your programs and how far the
proceeds from the offering will allow you to proceed with the continued development of
each of your programs.  Refer to Instruction 3 to Item 504 of Regulation S-K.
Major Vendor, page 52
8.We refer to your disclosure that a major vendor accounted for approximately 40% of your
research and development expenditures for the year ending December 31, 2020 and that
you expect to maintain this relationship.  Please expand your disclosure to discuss the
material terms of the agreement and file the agreement with this vendor as an exhibit to
the registration statement, or tell us why it is not material.

 FirstName LastNameDavid Luci
 Comapany NameAcurx Pharmaceuticals, LLC
 April 30, 2021 Page 3
 FirstName LastName
David Luci
Acurx Pharmaceuticals, LLC
April 30, 2021
Page 3
Business, page 53
9.Please clarify the meaning of scientific or technical terms the first time they are used in
the Business section in order to ensure that lay readers will understand the disclosure.  For
example, please briefly explain what you mean by NOAEL, PAE, time-kill kinetics and
non-inferiority clinical trial in your discussion.
10.We note your disclosure of your Scientific Advisory Board on page 53, in the Summary
and on your website.  If material, please include disclosure that describes the role or
function of your Scientific Advisors, whether there are any rules of procedures governing
this board as well as how the Scientific Advisors are compensated.
11.Please expand your disclosure in the Business section with respect to the log kill times and
log differences and how they relate to the FDA’s evidentiary standards of efficacy. For
example, we note your discussion on pages 59 and 60.
Our Technology, page 53
12.We note your disclosure of the asset purchase agreement you entered in to with
GLSynthesis, Inc. for the acquisition of ibezapolstat.  Please revise your disclosure to
include any up-front payments made, the royalty term, when the last-to-expire patent is
scheduled to expire and jurisdiction of the patent acquired.  Please also file the purchase
agreement as required by 601(b)(10) of Regulation S-K or explain to us why it is not
material.
13.We refer to your disclosure on page 54 that your Phase 1 trial data showed that dosages of
your lead product candidate were “safe and well tolerated” with an adverse event profile
similar to the placebo control group.  Please note that determinations of safety and
efficacy are solely within the authority of the FDA; therefore, please revise the prospectus
to remove all references and/or implications of safety and efficacy, including the reference
cited above.  Please also clarify your disclosure to specify if any serious adverse events
were observed with respect to your Phase 1 trial.
About QIDP and Fast Track Designations, page 55
14.We note your statement on page 56 that you believe that ACX-375C, which is “currently
in pre-clinical development, will also be eligible for FDA’s QIDP and fast track
designations” based on advice from your scientific advisors.  This statement suggests that
the product candidate is likely to be approved for QIDP and fast track designations.
Please expand your disclosure to specify the reasons that your scientific advisors provided
to support its conclusion.
In vivo Efficacy Animal Models, page 60
15.The graphics identified as Table 2 and Figure 2 on page 61 and the table on page 71
contain text that is illegible.  Please revise accordingly.

 FirstName LastNameDavid Luci
 Comapany NameAcurx Pharmaceuticals, LLC
 April 30, 2021 Page 4
 FirstName LastNameDavid Luci
Acurx Pharmaceuticals, LLC
April 30, 2021
Page 4
Competition, page 69
16.We note your statement that no new antibiotics in clinical development have shown
improvement in either initial cure rate (ICR) or sustained cure rate (SCR) in comparison
to currently marketed antibiotics.  Given that you have not identified or conducted head-
to-head trials with such new antibiotics, it does not appear appropriate to make these
comparisons.  Please delete this statement or tell us why you believe it is appropriate and
revise accordingly.  We also refer to the graphic on page 71.  We note that the first two
rows provide comparisons of currently marketed antibiotics against the current standard-
of-care antibiotic for CDI, vancomycin.  Please add a row showing a comparison of
ibezapolstat and another standard antibiotic as applicable.
Competitive Strengths, page 71
17.You disclose that you believe there is a “high probability” that your Phase 2b trial will be
successful.  Please explain the meaning of the “NI” term and the use of p-values and how
it relates to the FDA’s evidentiary standards of efficacy.
Intellectual Property and Market Exclusivity, page 71
18.We note your disclosure of two U.S. patents with claims that cover ibezapolstat and will
expire in May 2023 and September 2030.  You also disclose a key U.S. composition-of-
matter patent that expires in May 2032.  Please clarify your disclosure to specify the type
of patent protection provided to each of the U.S. patents issued.  Please also revise your
disclosure on page 72 to specify the number of your non-U.S. composition-of-matter
patents in Europe, Japan and Canada and the specific product or technology each of these
patents relate to.
19.You disclose on page 72 that you have filed a corresponding international patent
application with regard to ACX-375C that is currently pending.  Please expand your
disclosure to include the type of patent protection, expiration date and applicable
jurisdiction for this patent.
General
20.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
            You may contact Tracie Mariner at 202-551-3744 or Brian Cascio at 202-551-3676 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any other questions.

 FirstName LastNameDavid Luci
 Comapany NameAcurx Pharmaceuticals, LLC
 April 30, 2021 Page 5
 FirstName LastName
David Luci
Acurx Pharmaceuticals, LLC
April 30, 2021
Page 5
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Ivan Blumenthal, Esq.