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 Aligos Therapeutics, Inc.
 One Corporate Dr., 2nd Floor
 South San Francisco, CA 94080
 April 1, 2025 VIA EDGAR
 United States Securities and Exchange Commission Division of
Corporation Finance 100 F Street, N.E. Washington, D.C.
20549-6010

 Attention:

 Alan Campbell

 Re: 

 Aligos Therapeutics, Inc.

 Registration Statement on Form S-3 (Registration No. 333-286168)
 Ladies and Gentlemen:
 In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the
Registration Statement on Form S-3 (File No. 333-286168) (the “ Registration Statement ”) of Aligos Therapeutics, Inc. We respectfully request
that the Registration Statement become effective as of 4:00 p.m., Washington, D.C. time, on April 3, 2025, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with
our counsel, Latham & Watkins LLP, by calling Mark Roeder at (650) 463-3043. Thank you
for your assistance in this matter.

 Very truly yours,

 A LIGOS T HERAPEUTICS ,
I NC .

 By:

 /s/ Lesley Ann Calhoun

 Lesley Ann Calhoun

 Executive Vice President, Chief Operating Officer and Chief Financial Officer

 CC:
 Lawrence M. Blatt, Ph.D., Aligos Therapeutics, Inc.
 Mark V. Roeder, Latham & Watkins LLP
 John Williams, Latham & Watkins LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 1, 2025

Lawrence M. Blatt
Chairman, President and Chief Executive Officer
Aligos Therapeutics, Inc.
One Corporate Dr., 2nd Floor
South San Francisco, CA 94080

 Re: Aligos Therapeutics, Inc.
 Registration Statement on Form S-3
 Filed March 27, 2025
 File No. 333-286168
Dear Lawrence M. Blatt:

 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: John C. Williams, Esq.
</TEXT>
</DOCUMENT>

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 Aligos Therapeutics, Inc.

One Corporate Dr., 2nd Floor

South San Francisco, CA 94080

November 14, 2024

 VIA EDGAR AND E-MAIL

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-6010

 Attention:  Daniel
Crawford

Re:
 Aligos Therapeutics, Inc.

 
 Registration Statement on Form S-3 (Registration No. 333-283041)

 Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the
Registration Statement on Form S-3 (File No. 333- 283041) (the “Registration Statement”) of Aligos Therapeutics, Inc. We respectfully
request that the Registration Statement become effective as of 4:00 p.m., Washington, D.C. time, on November 18, 2024, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that
event with our counsel, Latham & Watkins LLP, by calling Mark Roeder at (650) 463-3043.

Thank you for your assistance in this matter.

 Very truly yours,

 ALIGOS THERAPEUTICS,
INC.

 By:

 /s/ Lesley Ann Calhoun

Lesley Ann Calhoun

Executive Vice President and Chief Financial Officer

CC:
 Lawrence M. Blatt, Ph.D., Aligos Therapeutics, Inc.

 
 Mark V. Roeder, Latham & Watkins LLP

 
 John Williams, Latham & Watkins LLP

November 13, 2024
Lawrence M. Blatt, Ph.D.
President and Chief Executive Officer
Aligos Therapeutics, Inc.
One Corporate Dr., 2nd Floor
South San Francisco, CA 94080
Re:Aligos Therapeutics, Inc.
Registration Statement on Form S-3
Filed November 6, 2024
File No. 333-283041
Dear Lawrence M. Blatt Ph.D.:
            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:Mark Roeder, Esq.

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 Aligos Therapeutics, Inc.

One Corporate Dr., 2nd Floor

 South
San Francisco, CA 94080

 November 22, 2023

 Via
EDGAR

 United States Securities and Exchange Commission

Division of Corporation Finance

 Office of Life Sciences

100 F Street, N.E.

 Washington, D.C. 20549

Attention: Tim Buchmiller

Re:
 Aligos Therapeutics, Inc.

Registration Statement on Form S-3

Filed November 17, 2023

Registration No. 333-275636

Dear Mr. Buchmiller:

 Pursuant to Rule
461(a) under the Securities Act of 1933, as amended, Aligos Therapeutics, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-referenced Registration Statement be accelerated by the
Securities and Exchange Commission to 4:00 p.m. Washington D.C. time on November 27, 2023, or as soon as practicable thereafter, or at such later time as the Company or its counsel may request via telephone call to the staff. Please contact
Mark V. Roeder of Latham & Watkins LLP, counsel to the Company, at (650) 463-3043, or in his absence, John C. Williams of Latham & Watkins LLP at (415)
395-8223, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.

Thank you for your assistance in this matter.

*        *
*        *

Sincerely,

Aligos Therapeutics, Inc.

By:

/s/ Lesley Ann Calhoun

Lesley Ann Calhoun

Executive Vice President, Chief Financial Officer

CC:
 Lawrence M. Blatt, Ph.D., Aligos Therapeutics, Inc.

Mark V. Roeder, Latham & Watkins LLP

John C. Williams, Latham & Watkins LLP

United States securities and exchange commission logo
November 21, 2023
Lawrence M. Blatt, Ph.D.
Chairman and Chief Executive Officer
Aligos Therapeutics, Inc.
One Corporate Dr., 2nd Floor
South San Francisco, CA 94080
Re:Aligos Therapeutics, Inc.
Registration Statement on Form S-3
Filed November 17, 2023
File No. 333-275636
Dear Lawrence M. Blatt:
            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 Tim Buchmiller at 202-551-3635 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark V. Roeder, Esq.

United States securities and exchange commission logo
December 27, 2022
Lesley Ann Calhoun
Chief Financial Officer
Aligos Therapeutics, Inc.
One Corporate Drive, 2nd Floor
South San Francisco, California
Re:Aligos Therapeutics, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed March 10, 2022
File No. 001-39617
Dear Lesley Ann Calhoun:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

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140 Scott Drive

Menlo Park, California 94025

Tel: +1.650.328.4600 Fax: +1.650.463.2600

www.lw.com

FIRM / AFFILIATE OFFICES

Austin

Milan

Beijing

Munich

Boston

New York

Brussels

Orange County

Century City

Paris

December 22, 2022

Chicago

Riyadh

Dubai

San Diego

VIA EDGAR

Düsseldorf

San Francisco

Frankfurt

Seoul

United States Securities and Exchange Commission

Hamburg

Shanghai

Division of Corporation Finance

Hong Kong

Silicon Valley

Office of Life Sciences

Houston

Singapore

100 F Street, N.E.

London

Tel Aviv

Washington, D.C. 20549-6010

Los Angeles

Tokyo

Madrid

Washington, D.C.

Attention:
   Li Xiao

Daniel Gordon

Re:
 Aligos Therapeutics, Inc.

Form 10-K for Fiscal Year Ended December 31, 2021

Filed March 10, 2022

File No. 001-39617

To the addressee set forth above:

 On behalf of
Aligos Therapeutics, Inc. (the “Company”), we are hereby responding to the comment letter to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31,
2021 received on December 8, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”). We have set forth below each of the numbered comments of your letter in
bold type followed by the Company’s responses thereto.

 Form 10-K for Fiscal Year Ended
December 31, 2021

 Management’s Discussion and Analysis of Financial Condition and Results of Operations Components of Our Results
of Operations

 Research and Development Expenses, page 107

1.
 Considering the significant research and development expenses you have historically incurred and expect to
continue to incur, in future filings, please expand your disclosures to include more disaggregated disclosures for your research and development expenses, for example by product candidates, by program, and or by nature of costs. Please also disclose
whether you track external costs by product candidates and or by program, and if not, please disclose that fact in future filings as well.

 December 22, 2022

Page
2

 Response: The Company respectfully acknowledges the Staff’s comment and the
Company undertakes to provide the tabular disclosure in the form presented on Annex A to this response letter in its future periodic reports filed with the Commission beginning with its Annual Report on Form
10-K for the fiscal year ending December 31, 2022 (the “2022 Form 10-K”). The Company further notes that it tracks direct external research
and development expenses on a program-specific basis (chronic hepatitis B, coronaviruses, non-alcoholic steatohepatitis and early-stage programs).

Consolidated Financial Statements Note 11. License and Collaboration Agreements Agreement with Merck, page 140

2. Please address the following comments with regard to your accounting and disclosures for the License and Research Collaboration Agreement with
Merck & Co.

•

 Please expand your future filings to describe all material terms of the agreement, including the specific
amount for the upfront payments, and the development and commercilaiton milestone payments. For the tiered royalty arrangement, please disclose the royalty term and quantification of the royalty rate, or a range no greater than 10 percentage points
per tier.

 Response: In response to the Staff’s comment, the Company respectfully advises the Staff that
the Company believes it has disclosed all material information relating to the exclusive License and Research Collaboration Agreement the Company entered into with Merck Sharp & Dohme Corp. (“Merck”), a subsidiary of
Merck & Co., Inc., in December 2020 (the “Original Agreement”) and which agreement was later amended in January 2022 (the “First Amendment” and together with the Original Agreement, the
“Merck Agreement”).

 Under the Merck Agreement, Merck and the Company will apply the Company’s oligonucleotide
platform technology to discover, research, optimize and develop oligonucleotides directed against Nonalcoholic Steatohepatitis (“NASH”) targets and up to one additional liver-based cardiometabolic and/or fibroses target. As
described in the Company’s public filings with the Commission, the Company is a clinical-stage biopharmaceutical company with a pipeline of research and development programs. This includes multiple drug candidates in clinical development and
drug candidates designed to address chronic hepatitis B, coronaviruses and NASH targets. The Merck Agreement relates to undisclosed NASH targets in early stages of the research and development process and the Company’s research and development
efforts under the Merck Agreement remain highly uncertain and may not be successful. Given the early stage of development and the risks involved in the drug development process, any potential future royalty and milestone payments under the Merck
Agreement are considered to be remote, highly speculative and cannot be reasonably predicted at this time. Given the early stage of development and the fact that this agreement relates to two of several programs under development at the Company, the
Company respectfully submits that the Company and its business are not substantially dependent on the Merck Agreement and that the Merck Agreement is not a material agreement to the Company.

 December 22, 2022

Page
3

 Although the Company does not believe the Merck Agreement is a material agreement, the
Company respectfully notes that it has disclosed in its filings with the Commission that, with respect to each target in the collaboration, the Company will be eligible to receive up to approximately $460.0 million in development, regulatory
and commercialization milestones as well as tiered royalties on net sales. In future periodic reports filed with the Commission, the Company plans to disclose the amount of upfront payments received by the Company under the Merck Agreement. If the
Company later determines that the Merck Agreement is a material agreement due to further development or other factors, the Company would expect to disclose additional terms of the Merck Agreement, including with respect to potential royalty and
milestone payments.

•

 Please provide us an analysis, and revise your future filings if necessary, of the components you have
identified under this agreement that would fall under ASC 808 Collaborative Arrangements and the components under ASC 606 Revenue from Contracts with Customers. In your analysis, tell us how you have
considered the unit of account guidance under ASC 808-10-15-5B.

Response: The Company respectfully acknowledges the Staff’s comment and notes that per the Company’s analysis, the agreements
with Merck fall under ASC 808, Collaborative Arrangements.

 The Company entered into the Original Agreement with Merck in December 2020
and, in January 2022, the Company entered into the First Amendment to the Original Agreement. For each of the Original Agreement and the First Amendment, the Company analyzed whether the agreement falls under ASC 808, Collaborative Arrangements, and
whether any component also fell under ASC 606, Revenue from Contracts with Customers. In each analysis, the Company and Merck are both active participants in various research activities, and both the Company and Merck are exposed to significant
risks and rewards. Each party is responsible for covering their own costs and the Company’s costs are not guaranteed to be covered by the upfront payment. Additionally, the Company may receive significant rewards in the form of milestone and
royalty payments if the target compounds continue in development, and Merck will receive cash flows from commercialization, if a drug candidate under the collaboration is approved and commercialized. As such, the Company concluded that each
arrangement falls under ASC 808.

 The Company concluded that neither the Original Agreement nor the First Amendment is in the scope of ASC
606 as Merck was not deemed to be a customer and the provision of research and development (“R&D”) services for others is not part of the Company’s ordinary activities. The Company analogizes to ASC 606 for certain
activities including the unit of account and recognition of revenue. Revenue recognized by analogizing to ASC 606 is recorded as “Revenue from collaborations”.

As per ASC
808-10-15-5B, the Company also assessed the performance obligations included in each agreement including a license of
intellectual property (“IP”), provision of R&D services and participation in a Joint Research Committee. Based on the Company’s analysis, the Company believes that Merck cannot benefit from the exclusive license on
its own, or with other resources readily available, as the license is to specific collaboration compounds discovered under this collaboration and being developed by both parties.

 December 22, 2022

Page
4

Because of the early stage of the development, the R&D services significantly customize the license. The Joint Research Committee is made up of members from Merck and the Company involved in
the research program and integrated within the provision of R&D activities. Further, the Joint Research Committee is not providing any separate or distinct service and will be disbanded at the end of the research program. Thus, the Company does
not consider the Joint Research Committee as a part of the overall contract to be material in the context of the Merck Agreement. Therefore, the Company considers the exclusive license of IP, provision of R&D services and participation in the
Joint Research Committee to be one single distinct unit of account under ASC 808-10-15-5B that is not within the scope of ASC 606
but the Company has accounted for it by analogy to ASC 606.

 The Company also assessed whether a contract modification had occurred in
January 2022 when the Company entered into the First Amendment. In this assessment, the Company noted that the First Amendment is for a different research target, and the project is managed by a separate individual at the Company than the Original
Agreement. The First Amendment was negotiated separately and the focus of the First Amendment is to produce a different compound with Merck. Additionally, the upfront payment was at a standalone selling price, separate and distinct from the upfront
payment already received for the Original Agreement. As such, the Company concluded the First Amendment to the Original Agreement was a separate and distinct arrangement, and a contract modification had not occurred under applicable accounting
standards.

 In future periodic reports filed with the Commission, the Company plans to disclose this arrangement as set forth in Annex
B to this response letter.

•

 Please tell us and revise in future filings the specific milestone payments achieved in 2021 and 2022. In that
regard, you repeatedly disclose that the revenues you have recognized so far are from milestone payments.

Response: The Company respectfully acknowledges the Staff’s comment and notes that all revenue recognized from the Merck Agreement
to date has been from upfront payments received from Merck, and not additional payments as a result of meeting any milestone targets. In future periodic reports filed with the Commission, the Company plans to disclose this as set forth in Annex
B to this response letter.

•

 Please provide us an analysis of your revenue recognition under ASC 606, including your determination of the
performance obligations, the transaction price, and your revenue recognition method (i.e. over time or point in time) for each performance obligation. In that regard, please note that the percentage of completion is not referred to as a revenue
recognition method under ASC 606.

 Response: The Company respectfully acknowledges the Staff’s comment.
The Company determined that both the Original Agreement and the First Amendment are not in the scope of ASC 606, but rather within the scope of ASC 808, and management analogizes to ASC 606 for certain elements as discussed in bullet two above.

 December 22, 2022

Page
5

At the inception of each contract with Merck, the Company considered all promises within the contract, and considered whether they are distinct. For each Merck arrangement, the Company considers
there to be a single performance obligation as described under the second bullet above. The Company considers the guidance in ASC 606 on transaction price by analogy, and notes that each contract involves both upfront payments, future potential
milestone payments and future potential royalty payments. At the inception of the Original Agreement and the First Amendment, both the milestone and royalty payments are considered remote as they are due based on future milestones not considered
probable of achievement at the time of researching a potential compound. As such, they are not recognized at this time. For the upfront payments, the Company analogizes to ASC 606 for the recognition of revenue and, as the performance obligation is
achieved over the research and development period, the input method of costs incurred is used.

 In future periodic reports filed with the
Commission, the Company plans to disclose this arrangement as set forth in Annex B to this response letter.

•

 Lastly, please revise your future filings to include a roll forward of your deferred revenue with the
movements agreeing to the payments received and revenue recognized during the period to meet the disclosure requirement under ASC 606-10-
50-8.

 Response: The Company respectfully acknowledges the
Staff’s comment and will include a roll forward of its deferred revenue from collaboration agreements in its future periodic reports filed with the Commission beginning with the 2022 Form 10-K, as set
forth in Annex B to this response letter.

 We hope the foregoing answers are responsive to your comments. Please do not hesitate to
contact me by telephone at (650) 463-3043 or by fax at (650) 463-2600 with any questions or comments regarding this correspondence.

Very truly yours,

 /s/ Mark V. Roeder

 Mark V. Roeder

 of LATHAM & WATKINS
LLP

cc:
 Lesley Ann Calhoun, Aligos Therapeutics, Inc.

Lucinda Quan, Aligos Therapeutics, Inc.

John Williams, Latham & Watkins LLP

 December 22, 2022

Page
6

 Annex A

Research and Development Expenses

Year ended
December 31,

2022

2021

 (audited)

(in thousands)

 Direct research and development expenses by development program:

 Chronic Hepatitis B program

$
XXX

$
XXX

 Coronaviruses program

XXX

XXX

 Non-alcoholic Steatohepatitis program

XXX

XXX

 Other early-stage programs

XXX

XXX

 Total direct research and development expenses

XXX

XXX

 Total indirect research and development expenses

XXX

XXX

Total research and development expense by development program

$ XXX

$ XXX

 Note: XXX in the above table represents illustrative financial information and the Company will populate financial numbers
when presented in its future filings, beginning with its 2022 Form 10-K.

 December 22, 2022

Page
7

 Annex B

Agreements with Merck

 In
December 2020, the Company and Merck Sharp & Dohme Corp. (“Merck”), a subsidiary of Merck & Co., Inc., entered into an exclusive License and Research Collaboration Agreement (“Original
Agreement”) under which Merck and the Company agreed to apply the Company’s oligonucleotide platform technology to discover, research, optimize and develop oligonucleotides directed against a NASH target and up to one additional
liver-targeted cardiometabolic and/or fibrosis target. Under the terms of the Original Agreement, the Company received an upfront payment of $12 million from Merck. With respect to the collaboration target, the Company is eligible to receive up
to $458.0 million in development and commercialization milestones as well as tiered royalties on net sales of licensed products. These potential payments consist of (i) potential development milestones (such as for the first dosing of an
animal specimen in a Good Laboratory Practice toxicology study, and

United States securities and exchange commission logo
December 8, 2022
Lesley Ann Calhoun
Chief Financial Officer
Aligos Therapeutics, Inc.
One Corporate Drive, 2nd Floor
South San Francisco, California
Re:Aligos Therapeutics, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed March 10, 2022
File No. 001-39617
Dear Lesley Ann Calhoun:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Components of Our Results of Operations
Research and Development Expenses, page 107
1.Considering the significant research and development expenses you have historically
incurred and expect to continue to incur, in future filings, please expand your disclosures
to include more disaggregated disclosures for your research and development expenses,
for example by product candidates, by program, and or by nature of costs. Please also
disclose whether you track external costs by product candidates and or by program, and if
not, please disclose that fact in future filings as well.

 FirstName LastNameLesley Ann  Calhoun
 Comapany NameAligos Therapeutics, Inc.
 December 8, 2022 Page 2
 FirstName LastName
Lesley Ann  Calhoun
Aligos Therapeutics, Inc.
December 8, 2022
Page 2
Consolidated Financial Statements
Note 11. License and Collaboration Agreements
Agreement with Merck, page 140
2.Please address the following comments with regard to your accounting and disclosures for
the License and Research Collaboration Agreement with Merck & Co.

•Please expand your future filings to describe all material terms of the agreement,
including the specific amount for the upfront payments, and the development and
commercilaiton milestone payments. For the tiered royalty arrangement, please
disclose the royalty term and quantification of the royalty rate, or a range no greater
than 10 percentage points per tier.
•Please provide us an analysis, and revise your future filings if necessary, of the
components you have identified under this agreement that would fall under ASC 808
Collaborative Arrangements and the components under ASC 606 Revenue from
Contracts with Customers. In your analysis, tell us how you have considered the unit
of account guidance under ASC 808-10-15-5B.
•Please tell us and revise in future filings the specific milestone payments achieved in
2021 and 2022. In that regard, you repeatedly disclose that the revenues you have
recognized so far are from milestone payments.
•Please provide us an analysis of your revenue recognition under ASC 606, including
your determination of the performance obligations, the transaction price, and your
revenue recognition method (i.e. over time or point in time) for each performance
obligation. In that regard, please note that the percentage of completion is not referred
to as a revenue recognition method under ASC 606.
•Lastly, please revise your future filings to include a roll forward of your deferred
revenue with the movements agreeing to the payments received and revenue
recognized during the period to meet the disclosure requirement under ASC 606-10-
50-8.
            In closing, 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.
            You may contact Li Xiao at 202-551-4391 or Daniel Gordon at 202-551-3486 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

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 Aligos Therapeutics, Inc.

One Corporate Dr., 2nd Floor

South San Francisco, CA 94080

November 17, 2021

 VIA EDGAR AND E-MAIL

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-6010

 Attention: Michael Davis

Re:
 Aligos Therapeutics, Inc.

Registration Statement on Form S-3 (Registration
No. 333-260774)

 Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the
Registration Statement on Form S-3 (File No. 333-260774) (the “Registration Statement”) of Aligos Therapeutics, Inc. We respectfully request
that the Registration Statement become effective as of 4:00 p.m., Washington, D.C. time, on November 19, 2021, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event
with our counsel, Latham & Watkins LLP, by calling Mark Roeder at (650) 463-3043.

 Thank
you for your assistance in this matter.

Very truly yours,

ALIGOS THERAPEUTICS, INC.

By:

 /s/ Lesley Ann Calhoun

Lesley Ann Calhoun

Executive Vice President, Chief Financial Officer

CC:
 Lawrence M. Blatt, Ph.D., Aligos Therapeutics, Inc.

Lucinda Quan, Aligos Therapeutics, Inc.

Mark V. Roeder, Latham & Watkins LLP

John Williams, Latham & Watkins LLP

United States securities and exchange commission logo
November 15, 2021
Lawrence Blatt, Ph.D.
Chief Executive Officer
Aligos Therapeutics, Inc.
One Corporate Dr., 2nd Floor
South San Francisco, CA 94080
Re:Aligos Therapeutics, Inc.
Registration Statement on Form S-3
Filed November 4, 2021
File No. 333-260774
Dear Dr. Blatt:
            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 Michael Davis at 202-551-4385 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark V. Roeder, Esq.

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 Aligos Therapeutics, Inc.

One Corporate Dr., 2nd Floor

South San Francisco, CA 94080

June 28, 2021

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Healthcare & Insurance

100 F Street, N.E.

 Washington, D.C. 20549-6010

Attention:      Laura Crotty

Re:
 Aligos Therapeutics, Inc. Registration Statement on Form S-1
(Registration No. 333-257466)

 Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby
request acceleration of the effective date of the Registration Statement on Form S-1 (File No. 333-257466) (the “Registration Statement”) of Aligos Therapeutics, Inc. (the
“Company”). We respectfully request that the Registration Statement become effective as of 4:30 p.m., Washington, D.C. time, on June 30, 2021, or as soon as practicable thereafter, or at such other time as our legal
counsel, Latham & Watkins LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel,
Latham & Watkins LLP, by calling Mark Roeder at (650) 463-3043 or John Williams at (415) 395-8223.

Thank you for your assistance in this matter.

Very truly yours,

Aligos Therapeutics, Inc.

By:

/s/ Lesley Ann Calhoun

Lesley Ann Calhoun

Executive Vice President, Chief Financial Officer

 CC:

 Lawrence M. Blatt, Ph.D., Aligos Therapeutics, Inc.

 Lucinda Y. Quan, Aligos Therapeutics, Inc.

 Mark Roeder, Latham & Watkins LLP

 John Williams, Latham & Watkins LLP

 Alan F. Denenberg, Davis Polk & Wardwell LLP

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 J.P. Morgan Securities LLC

383 Madison Avenue

 New York, NY 10179

Jefferies LLC

 520 Madison Avenue

New York, NY 10022

 Piper Sandler & Co.

800 Nicollet Mall

 Minneapolis, MN 55402

June 28, 2021

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Healthcare & Insurance

 100 F Street,
N.E.

 Washington, D.C. 20549

 Attention: Laura Crotty

Re:
 Aligos Therapeutics, Inc.

Registration Statement on Form S-1 (File
No. 333-257466)

 Request for Acceleration of Effective Date

Ladies and Gentlemen:

 In accordance with Rule
461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of Aligos Therapeutics, Inc. (the “Company”) for acceleration of the
effective date of the above-named Registration Statement so that it becomes effective at 4:30 PM, Washington D.C. time, on June 30, 2021, or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside
counsel, Latham & Watkins LLP, may request by telephone that such Registration Statement be declared effective.

 Pursuant to Rule
460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each Underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, 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 advise that they have complied and will continue to comply, and each underwriter has advised the undersigned that it has
complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

Very truly yours,

 J.P. MORGAN SECURITIES LLC

JEFFERIES LLC

 PIPER SANDLER & CO.

 As representatives of the several underwriters listed in Schedule 1 to the Underwriting
Agreement

J.P. MORGAN SECURITIES LLC

By:

/s/ Benjamin Burdett

Name: Benjamin Burdett

Title: Managing Director

JEFFERIES LLC

By:

/s/ Dustin Tyner

Name: Dustin Tyner

Title: Managing Director

PIPER SANDLER & CO.

By:

/s/ Chad Huber

Name: Chad Huber

Title: Managing Director

 [Signature Page to Underwriters’ Acceleration Request]

United States securities and exchange commission logo
June 10, 2021
Lawrence M. Blatt
Chief Executive Officer
Aligos Therapeutics, Inc.
One Corporate Dr., 2nd Floor
South San Francisco, CA 94080
Re:Aligos Therapeutics, Inc.
Draft Registration Statement
Submitted June 4, 2021
CIK No. 0001799448
Dear Dr. Blatt:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. 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 Laura Crotty at 202-551-7614 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark Roeder

CORRESP
1
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CORRESP

 J.P. Morgan Securities LLC

383 Madison Avenue

 New
York, New York 10179

 Jefferies LLC

520 Madison Avenue

 New
York, New York 10022

 Piper Sandler & Co.

800 Nicollet Mall, Suite 800

Minneapolis, Minnesota 55402

October 13, 2020

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Healthcare & Insurance

100 F Street, N.E.

 Washington, D.C. 20549-6010

 Attention:

 Vanessa Robertson

 Lynn Dicker

J. Nolan McWilliams

 Justin Dobbie

Re:
 Aligos Therapeutics, Inc.

Registration Statement on Form S-1 (Registration
No. 333-249077)

 Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we, as
representatives of the several underwriters, hereby join in the request of Aligos Therapeutics, Inc. (the “Company”) for acceleration of the effective date of the Registration Statement on Form
S-1 (File No. 333-249077) so that it becomes effective as of 4:30 PM, Washington, D.C. time, on October 15, 2020, or as soon as practicable thereafter, or at
such other time thereafter as the Company or its outside counsel, Latham & Watkins LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission.

Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we have carried out the
following distribution of the Company’s preliminary prospectus dated October 9, 2020:

(i)
 Dates of distribution: October 9, 2020 through the date hereof

(ii)
 Number of prospective underwriters to which the preliminary prospectus was furnished: 4

(iii)
 Number of preliminary prospectuses furnished to investors: approximately 628

(iv)
 Number of preliminary prospectuses distributed to others, including the Company, the Company’s counsel,
independent accountants and underwriters’ counsel: approximately 26

 The undersigned, as representatives of the
several underwriters, advise that they have complied and will continue to comply, and each other participating underwriter has advised the undersigned that it has complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [Signature Page Follows]

 Very truly yours,

 J.P. MORGAN
SECURITIES LLC

 JEFFERIES LLC

 PIPER SANDLER & CO.

 Acting on behalf of themselves and the

several underwriters

J.P. MORGAN SECURITIES LLC

By:

/s/ Benjamin Burdett

Name:

Benjamin Burdett

Title:

Managing Director

JEFFERIES LLC

By:

/s/ Dustin Tyner

Name:

Dustin Tyner

Title:

Managing Director

PIPER SANDLER & CO.

By:

/s/ Chad Huber

Name:

Chad Huber

Title:

Managing Director

 [Signature Page - Underwriters’ Acceleration Request]

CORRESP
1
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CORRESP

 Aligos Therapeutics, Inc.

One Corporate Dr., 2nd Floor

South San Francisco, CA 94080

October 13, 2020

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Healthcare & Insurance

100 F Street, N.E.

 Washington, D.C. 20549-6010

 Attention:

 Vanessa Robertson

 Lynn Dicker

J. Nolan McWilliams

 Justin Dobbie

Re:
 Aligos Therapeutics, Inc. Registration Statement on Form S-1
(Registration No. 333-249077)

 Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby
request acceleration of the effective date of the Registration Statement on Form S-1 (File No. 333-249077) (the “Registration
Statement”) of Aligos Therapeutics, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 4:30 PM, Washington, D.C. time, on October 15, 2020, or as soon as
practicable thereafter, or at such other time as our legal counsel, Latham & Watkins LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission. Once the Registration Statement has been declared effective,
please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Mark Roeder at (650) 463-3043 or John Williams at (415) 395-8223.

 Under separate cover, you will receive today a letter from the managing underwriters of the proposed offering joining in the
Company’s request for acceleration of the effectiveness of the Registration Statement.

 Thank you for your assistance in this matter.

 Very truly yours,

Aligos Therapeutics, Inc.

By:

/s/ Lesley Ann Calhoun

 Lesley Ann Calhoun

 Executive Vice President,
Chief Financial Officer

 CC:

 Lawrence M. Blatt, Ph.D., Aligos Therapeutics, Inc.

Lucinda Y. Quan, Aligos Therapeutics, Inc.

 Mark Roeder,
Latham & Watkins LLP

 John Williams, Latham & Watkins LLP

Alan Denenberg, Davis Polk & Wardwell LLP

CORRESP
1
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CORRESP

[***] Certain information in this document has been omitted and filed separately with the Securities and Exchange Commission. Confidential treatment has been requested by Aligos Therapeutics, Inc. with respect to portions of this
letter.

 140 Scott Drive

 Menlo Park,
California 94025

 Tel: +1.650.328.4600 Fax: +1.650.463.2600

www.lw.com

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 Washington, D.C.

 October 2, 2020

 Via
EDGAR and Electronic Delivery

 U.S. Securities and Exchange Commission

Division of Corporation Finance

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Washington, DC 20549-1090

FOIA Confidential Treatment Requested

Under 17 C.F.R §200.83

Attention:
 Vanessa Robertson

 Lynn Dicker

 J. Nolan McWilliams

 Justin Dobbie

Re:
 Aligos Therapeutics, Inc.

 Registration Statement on Form S-1

 Filed on September 25, 2020

 File No. 333-249077

Ladies and Gentlemen:

 On behalf of Aligos
Therapeutics, Inc. (the “Company”), set forth below is information in response to comment number 6 contained in the letter to the Company dated September 22, 2020 from the staff (the “Staff”) of
the Securities and Exchange Commission (the “Commission”) relating to the Draft Registration Statement on Form S-1 that was originally confidentially submitted to the Commission on
August 25, 2020 and, as subsequently revised, was publicly filed by the Company on September 25, 2020 (the “Registration Statement”). The supplemental response set forth below is based upon information provided to
Latham & Watkins LLP by the Company.

 On behalf of the Company, we are respectfully requesting confidential treatment for
specified portions of this letter pursuant to Rule 83 promulgated by the Commission (17 C.F.R. § 200.83). This letter is accompanied by such request for confidential treatment because of the commercially sensitive nature of the information
discussed in this letter. A redacted version of this letter will be filed with the Commission on EDGAR, omitting the confidential information.

 CONFIDENTIAL TREATMENT REQUESTED
BY

 ALIGOS THERAPEUTICS, INC.

ALGS-1001

 October 2, 2020

 Page
 2

 The Company’s discussion of its accounting for stock-based compensation is primarily
contained within the sections of the Registration Statement entitled “Management’s discussion and analysis of financial condition and results of operations—Critical accounting policies and use of
estimates—Stock-based compensation” and “—Determination of fair value of common stock” (the “MD&A”) and appears on pages 106 through 109 of the Registration
Statement.

 The Company confirms to the Staff that no price range has yet been provided in the preliminary prospectus included in the
Registration Statement. However, the Company has authorized us to inform the Staff supplementally that, based on consultations with the lead underwriters, input received from
testing-the-waters meetings, and considerations of the current market conditions, if the marketing of the initial public offering (the “IPO”)
were to commence today, the Company’s present view is that the estimated offering range would be $[***] to $[***] per share (the “Preliminary IPO Price Range”). The share numbers, Preliminary IPO Price Range,
exercise prices and fair values do not take into account a reverse stock split that the Company intends to implement in connection with the IPO.

The Company advises the Staff that the Preliminary IPO Price Range represents the Company’s current belief of what the indicative price
range in the preliminary prospectus may be, but that the actual indicative price range in the preliminary prospectus will not be determined until the Company completes a valuation process with the underwriters of the IPO, which is expected to occur
shortly before the printing of the preliminary prospectus for the IPO. Therefore, the Preliminary IPO Price Range is subject to further change as a result of various factors, including market conditions and subsequent developments with respect to
the Company’s business. Upon completion of this valuation process, the Company will narrow the indicative price range to establish a bona fide offering price range not to be greater than $[***] between the low end of the range and the top end
of the range.

 To assist the Staff in its evaluation of the Company’s accounting for stock-based compensation, the Company has
provided the analysis as set forth below.

 DETERMINATION OF FAIR VALUE OF COMMON STOCK

As described in the Registration Statement, the Company has historically determined the fair value of its common stock using methodologies,
approaches and assumptions consistent with the American Institute of Certified Public Accountants’ Accounting and Valuation Guide, Valuation of Privately-Held-Company Equity Securities Issued as Compensation (the “Practice
Guide”). Specifically, the fair value of the shares of common stock underlying the Company’s stock options has been determined by the Company’s Board of Directors (the “Board”) with input from
management. Because there has been no public market for the Company’s common stock, and in the absence of recent arm’s-length cash sales transactions of the Company’s common stock with
independent third parties, the Board, with input from management, has determined the fair value of the common stock by considering a number of objective and subjective factors, including independent third-party valuations as of October 11,
2018, December 24, 2019 and June 30, 2020. The Board gave consideration to expected material grants of common stock options in determining when to obtain independent third-party valuations.

 [***] Certain information in this document has been omitted and filed separately with the Securities and Exchange Commission. Confidential
treatment has been requested by Aligos Therapeutics, Inc. with respect to portions of this letter.

 CONFIDENTIAL TREATMENT REQUESTED
BY

 ALIGOS THERAPEUTICS, INC.

ALGS-1002

 October 2, 2020

 Page
 3

 As described in greater detail in the MD&A, these valuations have utilized combinations
of (i) the option-pricing method (“OPM”) and (ii) the probability-weighted expected return method (“PWERM”) for determining the fair value of the Company’s common stock. The OPM uses
option theory to value the various classes of a company’s securities in light of their respective claims to the company’s total stockholders’ equity. In particular, total stockholders’ equity value is allocated to the various
share classes based upon their respective claims on a series of call options with strike prices at various value levels depending upon the rights and preferences of each class of equity. Under the PWERM, the per share value of the common stock is
estimated based upon the probability-weighted present value of expected future equity values for the common stock, under various possible future liquidity event scenarios, in light of the rights and preferences of each class of equity, discounted
for a lack of marketability.

 For the October 2018 Valuation (as defined below), the Company utilized the OPM for determining the fair
value of the Company’s common stock. For the December 2019 Valuation (as defined below), the Company utilized a hybrid approach of the OPM and the PWERM, an accepted valuation approach under the Practice Guide, for determining the fair value of
the Company’s common stock (the “Hybrid Method”). The Hybrid Method is a PWERM where the equity value in one or more of the scenarios is calculated using an OPM. The Company determined to incorporate the PWERM into its
valuation methodology as values associated with various potential outcomes were considered estimable, based on the Company’s likelihood of achieving certain milestones set forth in the Series B Preferred Stock Purchase Agreement, dated
December 23, 2019, between the Company and the investors party thereto (the “Series B Purchase Agreement”). For the June 30, 2020 Valuation (as defined below), the Company utilized the PWERM approach for determining
the fair value of the Company’s common stock.

 At each grant date, the Board evaluated any recent events and their potential impact
on the estimated fair value per share of the common stock. For grants of stock awards made on dates for which there was no concurrent independent third-party valuation, the Board determined the fair value of the common stock on the date of grant
taking into consideration the immediately preceding valuation report as well as other pertinent information available at the time of the grant.

In the course of preparing the Company’s consolidated financial statements with a retrospective view, the Company also estimated the fair
value of its common stock for financial reporting purposes. For purposes of this determination with respect to the Company’s stock option grants on June 26, 2020, the Company assumed that the fair value of the common stock increased to the
valuation following the applicable grant. A combination of Company-specific factors, including a decision to begin preparations for a potential IPO, more certainty around the Company’s business and progress toward milestones under the Series B
Purchase Agreement as well as external market factors, led to the decision to use the June 30, 2020 Valuation when determining the fair value of the underlying common stock for financial reporting purposes.

 [***] Certain information in this document has been omitted and filed separately with the Securities and Exchange Commission. Confidential
treatment has been requested by Aligos Therapeutics, Inc. with respect to portions of this letter.

 CONFIDENTIAL TREATMENT REQUESTED
BY

 ALIGOS THERAPEUTICS, INC.

ALGS-1003

 October 2, 2020

 Page
 4

 GRANTS OF COMMON STOCK OPTIONS SINCE JANUARY 1, 2019

The following table summarizes by grant date the number of shares of common stock underlying stock options granted since January 1, 2019,
as well as the associated per share exercise price and the estimated fair value per share of the Company’s common stock on the grant date for financial reporting purposes.

 Grant Date

 Number of Shares

Underlying Stock

 Options
Granted

 Per Share

Exercise

 Price

 Estimated

Fair Value per Share

 for
Financial Reporting

 Purposes

 April 26, 2019

[***]

$[***]

$[***]

 May 14, 2019

[***]

$[***]

$[***]

 July 9, 2019

[***]

$[***]

$[***]

 August 13, 2019

[***]

$[***]

$[***]

 September 10, 2019

[***]

$[***]

$[***]

 September 17, 2019

[***]

$[***]

$[***]

 February 20, 2020

[***]

$[***]

$[***]

 March 10, 2020

[***]

$[***]

$[***]

 May 12, 2020

[***]

$[***]

$[***]

 June 10, 2020

[***]

$[***]

$[***]

 June 26, 2020

[***]

$[***]

$[***] (a)

(a)
 Fair value determined for financial reporting purposes, assuming that the fair value of the Company’s
common stock increased on June 26, 2020 to the fair value of its common stock as determined pursuant to the June 30, 2020 Valuation, which was $$[***] per share.

VALUATIONS AND OPTION GRANTS SINCE JANUARY 1, 2019

October 11, 2018 Valuation and April 26, 2019, May 14, 2019, July 9, 2019, August 13, 2019, September 10, 2019
and September 17, 2019 Grants

 A valuation was performed by the Company with the assistance of a third-party independent
valuation specialist that determined the fair value of the Company’s common stock as of October 11, 2018 to be $[***] per share (the “October 2018 Valuation”).

For the October 2018 Valuation, the Company utilized the OPM to determine the total implied enterprise value. The Company specifically
utilized the backsolve method. The backsolve method takes into account the economic rights of recently issued securities in relation to the rights of other equity securities within the capital structure. For purposes of the October 2018 Valuation,
the backsolve method reflected the Company’s Series A Convertible Preferred Stock financing.

 [***] Certain information in this document has been omitted and filed separately with the Securities and Exchange Commission. Confidential
treatment has been requested by Aligos Therapeutics, Inc. with respect to portions of this letter.

 CONFIDENTIAL TREATMENT REQUESTED
BY

 ALIGOS THERAPEUTICS, INC.

ALGS-1004

 October 2, 2020

 Page
 5

The implied enterprise value derived in the October 2018 Valuation was then adjusted based on a change in market conditions that occurred between the financing date and the valuation date. The
Company then employed the OPM to allocate the total stockholders’ equity value to the various classes of the Company’s stockholders based on their respective claims on a series of call options with strike prices at various value levels
depending on the rights and preferences of each class.

 In applying the OPM to the 2019 awards referenced above, the Company utilized an
estimated time to liquidity of [***] years, a risk free rate of [***]% and an estimated volatility of [***]%, which resulted in an estimated fair value of the Company’s common stock of $[***] per share, on a minority, marketable basis. In
determining the estimated fair value of the common stock, the Board and the third-party valuation firm also considered the fact that the Company’s stockholders could not freely trade the common stock in the public markets. Because the common
stock represented a non-marketable equity interest in a private enterprise, a discount for lack of marketability (“DLOM”) of [***]% was applied to the estimated fair value of the common
stock on a marketable basis, resulting in an estimated fair value of the common stock of $[***] per share on a minority, non-marketable basis. The DLOM was estimated based on consideration of a differential
put analysis in which the discount is estimated based on the difference between the protective put discount that would be estimated for the preferred stock and the discount that would be estimated for the common stock.

In connection with the grants of stock options made on April 26, 2019, May 14, 2019, July 9, 2019, August 13, 2019,
September 10, 2019 and September 17, 2019, the Board, with input from management, concluded that the estimated fair value of the Company’s common stock was $[***] per share in consideration of the valuation analysis as of
October 11, 2018 and other objective and subjective factors described on page 107 of the Registration Statement. During the period from the October 2018 Valuation to each of the grants in 2019 ending with the grant on September 17, 2019,
the Board concluded that there had not been a material change to the fair value of the Company’s common stock. During this period, the Company continued to progress in its research and development efforts, but no event or events occurred during
this period that caused the Board to conclude that there had been a material change to the fair value of the Company’s common stock.

December 24, 2019 Valuation and February 20, 2020, March 10, 2020, May 12, 2020, June 10, 2020 and June 26,
2020 Grants

 A valuation was performed by the Company with the assistance of a third-party independent valuation specialist that
determined the fair value of the Company’s common stock as of December 24, 2019 to be $[***] per share (the “December 2019 Valuation”).

 [***] Certain information in this document has been omitted and filed separately with the Securities and Exchange Commission. Confidential
treatment has been requested by Aligos Therapeutics, Inc. with respect to portions of this letter.

 CONFIDENTIAL TREATMENT REQUESTED
BY

 ALIGOS THERAPEUTICS, INC.

ALGS-1005

 October 2, 2020

 Page
 6

 For the December 2019 Valuation, the Company employed the Hybrid Method to compute the
probability-weighted value of the common stock acro

CORRESP
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filename1.htm

CORRESP

 140 Scott Drive

 Menlo Park,
California    94025

 Tel: +1.650.328.4600    Fax: +1.650.463.2600

www.lw.com

FIRM / AFFILIATE OFFICES

 Beijing

 Boston

Brussels

 Century City

Chicago

 Dubai

 Moscow

 Munich

New York

 Orange County

Paris

 Riyadh

September 25, 2020

 Düsseldorf

 Frankfurt

Hamburg

 Hong Kong

Houston

 London

Los Angeles

 Madrid

Milan

 Tokyo

 Washington, D.C.

Singapore

 Silicon Valley

Shanghai

 Seoul

San Francisco

 San Diego

 VIA EDGAR AND OVERNIGHT DELIVERY

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549-6010

Attention:
 Vanessa Robertson

Lynn Dicker

 J. Nolan McWilliams

 Justin Dobbie

Re:
 Aligos Therapeutics, Inc.

Draft Registration Statement on Form S-1

Confidentially submitted on August 25, 2020

CIK No. 0001799448

 Ladies and
Gentlemen:

 On behalf of our client, Aligos Therapeutics, Inc. (the “Company”), we are hereby filing a
Registration Statement on Form S-1 (the “Registration Statement”). The Company previously submitted a Draft Registration Statement on Form S-1 on
August 25, 2020 (the “Draft Submission”) to the U.S. Securities and Exchange Commission (the “Commission”) on a confidential basis pursuant to Title I, Section 106 under the Jumpstart Our
Business Startups Act. The Registration Statement has been revised to reflect the Company’s responses to the comment letter to the Draft Submission dated September 22, 2020 from the staff of the Commission (the
“Staff”). For your convenience, we are providing by overnight delivery a courtesy package that includes copies of the Registration Statement, including copies which have been marked to show changes from the Draft Submission,
as well as copy of this letter.

 For ease of review, we have set forth below each of the numbered comments of your letter in bold type
followed by the Company’s responses thereto.

 September 25, 2020

 Page
 2

 Prospectus Summary, page 1

1.
 Please revise the first paragraph of the Overview to clarify that your Phase 1 proof of concept trial for
your STOPS molecule is taking place in New Zealand.

 Response:    In response to the
Staff’s comment, the Company has revised pages 1, 94 and 111 of the Registration Statement.

2.
 Refer to the pipeline table on pages 2, 109, and 117. Please add a column to reflect phase 3 pivotal trials
to more accurately reflect each candidate’s stage of development. Also revise the position of the arrow for ALG-010133 or tell us why this placement is appropriate given you are still enrolling phase 1
study participants.

 Response:    In response to the Staff’s comment, the Company
has revised pages 2, 111 and 119 of the Registration Statement.

3.
 Please revise the first full paragraph on page 5 to clarify that your third area of focus is in a very early
stage of development.

 Response:    In response to the Staff’s comment, the Company
has revised pages 5 and 114 of the Registration Statement.

 Implications of being an emerging growth company, page 7

4.
 Please provide us 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, present to potential investors in reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communications. Please contact Nolan McWilliams at the number
below to discuss how to submit the materials, if any, for our review.

 Response:    The
Company respectfully acknowledges the Staff’s comment and undertakes that it will provide to the Staff supplementally copies of all written communications presented by the Company, or anyone authorized by the Company, to potential investors in
reliance on Section 5(d) of the Securities Act.

 Use of proceeds, page 83

5.
 Refer to the first five bullet points. You state that you intend to use net proceeds to “advance”
the respective candidate. To the extent known, please provide greater specificity how far in the development process you expect to advance each candidate with the proceeds of the offering.

Response:    The Company respectfully advises the Staff that at this stage of development, the Company is unable to
reasonably project how far in the development process the Company expects to advance each drug candidate with the net proceeds from the offering.

 September 25, 2020

 Page
 3

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

 Critical accounting policies and use of estimates

Stock-based compensation, page 104

6.
 Once you have an estimated offering price or range, please explain to us how you determined the fair value
of the common stock underlying your equity issuances and the reasons for any differences between the recent valuations of your common stock leading up to the IPO and the estimated offering price. This information will help facilitate our review of
your accounting for equity issuances including stock compensation and beneficial conversion features.

Response:    The Company respectfully acknowledges the Staff’s comment and undertakes that, once an estimated
offering price or range is available, it will provide the Staff with an analysis explaining the reasons for any differences between the Company’s recent fair value determinations and the estimated offering price, if any.

Business

 Our approach to research
and development, page 113

7.
 Refer to the last full paragraph on page 113. Please substantiate that you will be able to “develop . .
. candidates with potential potency and safety advantages over other development candidates.”

Response:    In response to the Staff’s comment, the Company has revised page 115 of the Registration
Statement to remove the applicable statement from the Registration Statement.

 Functional cure for CHB, page 117

8.
 You state that enrollment is ongoing for the phase 1 ALG-010133
trial. Please disclose the anticipated completion date for phase 1, or, if unknown, discuss the extent of uncertainty because enrollment is still ongoing. We note the last paragraph of the carryover risk factor on pages 27-28.

 Response:    In response to the Staff’s
comment, the Company has revised page 120 of the Registration Statement.

 siRNA, page 125

9.
 Refer to the last paragraph on page 126. Please briefly discuss the basis for your belief that your approach
to developing siRNAs “may have safety, stability, and potency advantages over ASOs and other siRNAs.”

 September 25, 2020

 Page
 4

 Response:    In response to the Staff’s comment, the Company
has revised page 127 of the Registration Statement to remove the applicable statement from the Registration Statement.

 Principal stockholders,
page 183

10.
 Beneficial ownership is not determined by reference to pecuniary interest for the purposes of Exchange Act
Rule 13d-3. Please revise footnotes (2), (3), and (4) accordingly.

Response:    In response to the Staff’s comment, the Company has revised page 186 of the Registration
Statement.

 Description of capital stock

Choice of forum, page 191

11.
 You state that the federal district courts will be the exclusive forum for claims under the Securities Act.
Please state here and in the carryover risk factor on pages 78-79 that stockholders will not be deemed to have waived the company’s compliance with the federal securities laws. Please also revise the
description of the provision here and in the risk factor referenced above for consistency.

Response:    In response to the Staff’s comment, the Company has revised pages 78, 79, 192 and 193 of the
Registration Statement.

 Exhibits

12.
 Please file the KU Leuven Agreement as an exhibit to the registration statement.

Response:    In response to the Staff’s comment, the Company respectfully advises the Staff
that it does not believe that the agreement the Company entered into with KU Leuven to research and develop potential protease inhibitors for the treatment, diagnosis, prediction, detection or prevention of coronaviruses, including SARS-CoV-2 (the “KU Leuven Agreement”) is a material contract under Item 601(b)(10) of Regulation S-K. Item 601(b)(10)(ii) of
Regulation S-K states that “[I]f the contract is such as ordinarily accompanies the kind of business conducted by the registrant and its subsidiaries, it will be deemed to have been made in the ordinary
course of business and need not be filed unless it falls within one or more of the following categories, in which case it shall be filed except where immaterial in amount or significance.”

Contracts Not Made Outside the Ordinary Course of Business

The Company advises the Staff that the KU Leuven Agreement was not entered into outside the ordinary course of business. As
described in the Registration Statement, the Company is a clinical-stage biopharmaceutical company with a pipeline of research and development programs. From time to time, the Company’s research and

 September 25, 2020

 Page
 5

development of drug candidates may involve collaboration with third parties to leverage their capabilities and resources and the in-license of intellectual
property rights from other third parties. In this respect, the Company also notes that the potential payment obligations for the Company are consistent with a contract that ordinarily accompanies the kind of business conducted by the Company. As
noted in the Registration Statement, the Company is obligated to make payments to KU Leuven, in aggregate, totaling up to but no more than $30,000 upon the achievement of certain commercial sales milestones. For each licensed product developed
through KU Leuven and the Company’s collaborative effort, the Company is obligated to make payments to KU Leuven, in aggregate, totaling up to $32,000 upon the achievement of certain development and regulatory milestones. The Company is also
required to pay KU Leuven a low-to-mid-single digit royalty percentage, subject to certain adjustments, on net sales of
applicable products, if any. For these reasons, the Company respectfully submits that the KU Leuven Agreement was not entered into outside the ordinary course of its business.

The Company’s Business is Not Substantially Dependent on the KU Leuven Agreement

Subsection (B) of Item 601(b)(10)(ii) states that a contract entered into in the ordinary course of business would be a
“material contract” if such contract is a “contract upon which the registrant’s business is substantially dependent, as in the case of continuing contracts to sell the major part of registrant’s products or services or to
purchase the major part of registrant’s requirements of goods, services or raw materials or any franchise or license or other agreement to use a patent, formula, trade secret, process or trade name upon which registrant’s business depends
to a material extent.”

 The Company respectfully advises the Staff that the Company’s business is not
substantially dependent on the KU Leuven Agreement. This agreement relates to the Company’s research and development of potential protease inhibitors for the treatment of coronaviruses, including SARS-CoV-2. As the Company states in the Registration Statement, “[w]e are in the earliest stages of our collaboration under the KU Leuven” and the Company’s research and development efforts
for the treatment of coronaviruses may not be successful. In addition, these efforts involve other approaches to treating coronaviruses that the Company is researching, such as leveraging its oligonucleotide platform and evaluating oligonucleotides
with the goal of identifying a suitable lead sequence for further optimization into a drug candidate and the Company may pursue these other approaches to treating coronavirus instead of small molecule, protease inhibitors that inhibit the 3C-like protease which are covered by the KU Leuven Agreement. Furthermore, the Company notes that it is developing drug candidates for the treatment of Chronic Hepatitis B and
non-alcoholic steatohepatitis that are in later stages of development, relative to the Company’s coronavirus research efforts. As such, the Company respectfully submits that the Company and its business
are not substantially dependent on the KU Leuven Agreement and that filing the KU Leuven Agreement as a material contract would not enable investors to form a more informed view of the Company’s business as a whole.

 September 25, 2020

 Page
 6

 General

13.
 Please provide mockups of any pages that include any additional pictures or graphics to be presented,
including any accompanying captions. For guidance, refer to Securities Act Forms Compliance and Disclosure Interpretation 101.02.

Response:    The Company acknowledges the Staff’s comment and respectfully advises the Staff that it does not
currently intend to include any additional graphic, visual or photographic information in the printed prospectus. If, following the date of this letter, the Company determines to include additional graphic, visual or photographic information in the
printed prospectus, it will provide proofs to the Staff prior to their use.

 * * *

 September 25, 2020

 Page
 7

 We hope the foregoing answers are responsive to your comments. Please do not hesitate to
contact me by telephone at (650) 463-3043 or by fax at (650) 463-2600 with any questions or comments regarding this correspondence.

Very truly yours,

/s/ Mark V. Roeder

Mark V. Roeder

of LATHAM & WATKINS LLP

cc:
 Lawrence M. Blatt, Aligos Therapeutics, Inc.

Lesley Ann Calhoun, Aligos Therapeutics, Inc.

Lucinda Y. Quan, Aligos Therapeutics, Inc.

John C. Williams, Latham & Watkins LLP

Alan F. Denenberg, Davis Polk & Wardwell LLP

United States securities and exchange commission logo
September 22, 2020
Lawrence M. Blatt, Ph.D
Chief Executive Officer
Aligos Therapeutics, Inc.
One Corporate Drive, 2nd Floot
South San Francisco, CA 94080
Re:Aligos Therapeutics, Inc.
Draft Registration Statement on Form S-1
Submitted August 26, 2020
CIK No. 0001799448
Dear Dr. Blatt:
            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
Prospectus Summary, page 1
1.Please revise the first paragraph of the Overview to clarify that your Phase 1 proof of
concept trial for your STOPS molecule is taking place in New Zealand.
2.Refer to the pipeline table on pages 2, 109, and 117.  Please add a column to reflect phase
3 pivotal trials to more accurately reflect each candidate’s stage of development.   Also
revise the position of the arrow for ALG-010133 or tell us why this placement is
appropriate given you are still enrolling phase 1 study participants.
3.Please revise the first full paragraph on page 5 to clarify that your third area of focus is in
a very early stage of development.

 FirstName LastNameLawrence M. Blatt, Ph.D
 Comapany NameAligos Therapeutics, Inc.
 September 22, 2020 Page 2
 FirstName LastName
Lawrence M. Blatt, Ph.D
Aligos Therapeutics, Inc.
September 22, 2020
Page 2
Implications of being an emerging growth company, page 7
4.Please provide us 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, present to potential
investors in reliance on Section 5(d) of the Securities Act, whether or not they retain
copies of the communications.  Please contact Nolan McWilliams at the number below to
discuss how to submit the materials, if any, for our review.
Use of proceeds, page 83
5.Refer to the first five bullet points.  You state that you intend to use net proceeds to
“advance” the respective candidate.  To the extent known, please provide greater
specificity how far in the development process you expect to advance each candidate with
the proceeds of the offering.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical accounting policies and use of estimates
Stock-based compensation, page 104
6.Once you have an estimated offering price or range, please explain to us how you
determined the fair value of the common stock underlying your equity issuances and the
reasons for any differences between the recent valuations of your common stock leading
up to the IPO and the estimated offering price.  This information will help facilitate our
review of your accounting for equity issuances including stock compensation and
beneficial conversion features.
Business
Our approach to research and development, page 113
7.Refer to the last full paragraph on page 113.  Please substantiate that you will be able to
“develop . . . candidates with potential potency and safety advantages over other
development candidates.”
Functional cure for CHB, page 117
8.You state that enrollment is ongoing for the phase 1 ALG-010133 trial.  Please disclose
the anticipated completion date for phase 1, or, if unknown, discuss the extent of
uncertainty because enrollment is still ongoing.  We note the last paragraph of the
carryover risk factor on pages 27-28.
siRNA, page 125
9.Refer to the last paragraph on page 126.  Please briefly discuss the basis for your belief
that your approach to developing siRNAs “may have safety, stability, and potency
advantages over ASOs and other siRNAs.”

 FirstName LastNameLawrence M. Blatt, Ph.D
 Comapany NameAligos Therapeutics, Inc.
 September 22, 2020 Page 3
 FirstName LastName
Lawrence M. Blatt, Ph.D
Aligos Therapeutics, Inc.
September 22, 2020
Page 3
Principal stockholders, page 183
10.Beneficial ownership is not determined by reference to pecuniary interest for the purposes
of Exchange Act Rule 13d-3.  Please revise footnotes (2), (3), and (4) accordingly.
Description of capital stock
Choice of forum, page 191
11.You state that the federal district courts will be the exclusive forum for claims under the
Securities Act.  Please state here and in the carryover risk factor on pages 78-79 that
stockholders will not be deemed to have waived the company’s compliance with the
federal securities laws.  Please also revise the description of the provision here and in the
risk factor referenced above for consistency.
Exhibits
12.Please file the KU Leuven Agreement as an exhibit to the registration statement.
General
13.Please provide mockups of any pages that include any additional pictures or graphics to be
presented, including any accompanying captions.  For guidance, refer to Securities Act
Forms Compliance and Disclosure Interpretation 101.02.
            You may contact Vanessa Robertson, Staff Accountant, at (202) 551-3649 or Lynn
Dicker, Staff Accountant, at (202) 551-3616 if you have questions regarding comments on the
financial statements and related matters.  Please contact J. Nolan McWilliams, Attorney-
Advisor, at (202) 551-3217 or Justin Dobbie, Legal Branch Chief, at (202) 551-3469 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Mark V. Roeder, Esq.