SecProbe.io

CORRESP
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 INMED PHARMACEUTICALS INC.
 Suite 1445 – 885 West Georgia St.

 Vancouver, British Columbia, Canada

 V6C 3E8

 VIA EDGAR

 July 31, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

 Re: InMed Pharmaceuticals Inc. – Withdrawal of Acceleration

Request for Registration Statement on Form S-1
Originally Filed on July 9, 2025

 and

 Acceleration Request for Pre-Effective Amendment No.
1 to
 Registration Statement on Form S-1

 Filed July 31, 2025

 File No. 333-288594

 Ladies and Gentlemen:

 InMed Pharmaceuticals Inc. (the " Company ")
hereby respectfully withdraws its request, previously submitted to the Securities and Exchange Commission (the " Commission ")
on July 14, 2025 (the " Prior Acceleration Request "), for the effectiveness of the Company's Registration
Statement on Form S-1 (File No. 333-288594) originally filed with the Commission on July 9, 2025 (the " Registration Statement ")
be accelerated to occur at 5:00 p.m. (Eastern Time) on July 16, 2025 at 5:00 p.m., or as soon thereafter as practicable.

 The Company has filed a Pre-Effective
Amendment No. 1 to the Registration Statement via EDGAR on the date hereof and, pursuant to Rule 461 under the Securities Act of
1933, as amended, the Company hereby now requests that the effective date and time of the Registration Statement be accelerated to
5:00 p.m. (Eastern Time) on August 1, 2025, or as soon thereafter as practicable. This letter supercedes and replaces the Prior
Acceleration Request in its entirety.

 If you have any questions regarding this request,
please contact Scott R. Saks of Norton Rose Fulbright US LLP at (212) 318-3151.

 Sincerely,

 INMED PHARMACEUTICALS INC.

 /s/ Eric A. Adams

 Eric A. Adams

 President and Chief Executive Officer

 cc:
 Netta Jagpal, InMed Pharmaceuticals Inc.

 Scott R. Saks, Norton Rose Fulbright US LLP

 Trevor Zeyl, Norton Rose Fulbright Canada LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 14, 2025

Eric Adams
Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 1445 885 West Georgia St.
Vancouver, British Columbia, Canada V6C 3E8

 Re: InMed Pharmaceuticals Inc.
 Registration Statement on Form S-1
 Filed July 9, 2025
 File No. 333-288594
Dear Eric Adams:

 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 Tyler Howes at 202-551-3370 with any questions.

 Sincerely,

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

CORRESP
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 filename1.htm

 INMED PHARMACEUTICALS INC.
 Suite 1445 – 885 West Georgia St.

 Vancouver, British Columbia, Canada

 V6C 3E8

 VIA EDGAR

 July 14, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

 Re: InMed Pharmaceuticals Inc.

 Acceleration Request for Registration Statement on Form
S-1

 Filed July 9, 2025

 File No. 333-288594

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended, InMed Pharmaceuticals Inc. hereby requests that the effective date and time of the above-referenced registration
statement be accelerated to July 16, 2025, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable.

 If you have any questions regarding this request,
please contact Scott R. Saks of Norton Rose Fulbright US LLP at (212) 318-3151.

 Sincerely,

 INMED PHARMACEUTICALS INC.

 /s/ Eric A. Adams

 Eric A. Adams

 President and Chief Executive Officer

 cc:
 Netta Jagpal, InMed Pharmaceuticals Inc.

 Scott R. Saks, Norton Rose Fulbright US LLP

 Trevor Zeyl, Norton Rose Fulbright Canada LLP

CORRESP
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INMED PHARMACEUTICALS INC.

Suite 1445 – 885 West Georgia St.

Vancouver, British Columbia, Canada

V6C 3E8

VIA EDGAR

December 30, 2024

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: InMed Pharmaceuticals Inc.

Acceleration Request for Registration Statement on Form
S-1

Filed December 23, 2024 (as amended by Pre-Effective

Amendment
No. 1 filed on December 30, 2024)

File No. 333-284029

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, InMed Pharmaceuticals Inc. hereby requests that the effective date and time of the above-referenced registration
statement be accelerated to December 31, 2024, at 4:30 p.m., Eastern Time, or as soon thereafter as practicable.

If you have any questions regarding this request,
please contact Jared D. Kaplan of Norton Rose Fulbright US LLP at (312) 964-7754.

    Sincerely,

    INMED PHARMACEUTICALS INC.

    /s/ Eric A. Adams

    Eric A. Adams

    President and Chief Executive Officer

    cc:
    Netta Jagpal, InMed Pharmaceuticals Inc.

    Jared D. Kaplan, Norton Rose Fulbright US LLP

    Trevor Zeyl, Norton Rose Fulbright Canada LLP

December 27, 2024
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 1445 – 885 West Georgia St.
Vancouver, British Columbia, Canada V6C 3E8
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed December 23, 2024
File No. 333-284029
Dear Eric A. Adams:
            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:Jared Kaplan

United States securities and exchange commission logo
November 9, 2023
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310 – 815 West Hastings Street
Vancouver, British Columbia V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed November 8, 2023
File No. 333-275410
Dear Eric A. Adams:
            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 Joshua Gorsky at 202-551-7836 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Brian Fenske

CORRESP
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INMED PHARMACEUTICALS INC.

Suite 310 - 815 West Hastings Street

Vancouver, British Columbia, Canada

V6C 1B4

VIA EDGAR

November 9, 2023

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: InMed Pharmaceuticals Inc.

Acceleration Request for Registration Statement on Form S-1

Filed November 8, 2023

File No. 333-275410

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
InMed Pharmaceuticals Inc. hereby requests that the effective date and time of the above-referenced registration statement be accelerated
to November 13, 2023, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable.

If you have any questions regarding this request, please contact Brian
Fenske of Norton Rose Fulbright US LLP at (713) 651 5557.

    Sincerely,

    INMED PHARMACEUTICALS INC.

    /s/ Eric A. Adams

    Eric A. Adams

    President and Chief Executive Officer

 cc: Jonathan Tegge, InMed Pharmaceuticals Inc.

Brian Fenske, Norton Rose Fulbright US LLP

United States securities and exchange commission logo
December 12, 2022
Eric Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310 - 815 West Hastings Street
Vancouver, British Columbia, Canada
V6C 1B4
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed December 7, 2022
File No. 333-268700
Dear Eric Adams:
            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 Jason Drory at 202-551-8342 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Brian P. Fenske

CORRESP
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INMED PHARMACEUTICALS INC.

Suite 310 - 815 West Hastings Street

Vancouver, British Columbia, Canada

V6C 1B4

VIA EDGAR

December 12, 2022

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: InMed Pharmaceuticals Inc.

Acceleration Request for Registration Statement on Form S-1

Filed December 7, 2022

File No. 333-268700

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
InMed Pharmaceuticals Inc. hereby requests that the effective date and time of the above-referenced registration statement be accelerated
to December 14, 2022, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable.

If you have any questions regarding this request, please contact Brian
Fenske of Norton Rose Fulbright US LLP at (713) 651 5557.

    Sincerely,

    INMED PHARMACEUTICALS INC.

    /s/ Eric A. Adams

    Eric A. Adams

    President and Chief Executive Officer

cc: Sarah Li, InMed Pharmaceuticals Inc.

Brian Fenske, Norton Rose Fulbright US LLP

CORRESP
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INMED PHARMACEUTICALS INC.

Suite 310 - 815 West Hastings Street

Vancouver, British Columbia, Canada

V6C 1B4

VIA EDGAR

October 14, 2022

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: InMed Pharmaceuticals Inc.

Acceleration Request for Registration Statement on Form S-1

Filed October 12, 2022

File No. 333-267831

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended,
InMed Pharmaceuticals Inc. hereby requests that the effective date and time of the above-referenced registration statement be accelerated
to October 18, 2022, at 5:00 p.m., Eastern Time, or as soon thereafter as practicable.

If you have any questions regarding this request, please contact Brian
Fenske of Norton Rose Fulbright US LLP at (713) 651 5557.

    Sincerely,

    INMED PHARMACEUTICALS INC.

    /s/ Eric A. Adams

    Eric A. Adams

    President and Chief Executive Officer

cc: Brenda Edwards, InMed Pharmaceuticals Inc.

Brian Fenske, Norton Rose Fulbright US LLP

United States securities and exchange commission logo
October 14, 2022
Brenda Edwards
Interim Chief Financial Officer
InMed Pharmaceuticals Inc.
Suite 310 - 815 West Hastings Street
Vancouver, British Columbia, Canada
V6C 1B4
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed October 12, 2022
File No. 333-267831
Dear Brenda Edwards:
            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 Dillon Hagius at 202-551-7967 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Brian P. Fenske

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June 27, 2022

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

    Re:

    InMed Pharmaceuticals Inc.

    Registration Statement on Form S-1, filed on June 21, 2022

    As amended by Amendment No. 1 to the Registration Statement on Form
    S-1, filed on June 24, 2022

    File No. 333-265731

Ladies and Gentlemen:

On behalf of InMed Pharmaceuticals
Inc., a British Columbia corporation (the “Company”), the undersigned hereby respectfully submits its request
for acceleration of effectiveness. Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby
requests that the effective date of the above referenced Registration Statement on Form S-1, as amended (the “Registration
Statement”), be accelerated so that the same will become effective at 4:00 p.m., Washington, D.C. time, on Wednesday, June
29, 2022, or as soon as practicable thereafter.

Please notify Brian P. Fenske
of Norton Rose Fulbright US LLP, counsel to the Company, at (713) 651-5557 or at brian.fenske@nortonrosefulbright.com, as soon as the
Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

    Very truly yours,

    InMed Pharmaceuticals Inc.

    By:
    /s/ Eric A. Adams

    Name:
    Eric A. Adams

    Title:
    President and Chief Executive Officer

United States securities and exchange commission logo
June 23, 2022
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
815 W. Hastings Street, Suite 310
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed June 21, 2022
File No. 333-265731
Dear Mr. Adams:
            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 Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Brian Fenske, Esq.

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April 14, 2022

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

    Re:

    InMed Pharmaceuticals Inc.

    Registration Statement on Form S-3

    Filed April 7, 2022

    File No. 333-264187

Ladies and Gentlemen:

On behalf of InMed Pharmaceuticals Inc., a British
Columbia corporation (the “Company”), the undersigned hereby respectfully submits its request for acceleration
of effectiveness. Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that
the effective date of the above referenced Registration Statement on Form S-3 (the “Registration Statement”),
be accelerated so that the same will become effective at 4:00 p.m., Washington, D.C. time, on Monday, April 18, 2022, or as soon as practicable
thereafter.

Please notify Brian P. Fenske of Norton Rose Fulbright
US LLP, counsel to the Company, at (713) 651-5557, as soon as the Registration Statement has been declared effective, or if you have any
other questions or concerns regarding this matter.

    Very truly yours,

    InMed Pharmaceuticals Inc.

    By:
    /s/ Eric A. Adams

    Name:
    Eric A. Adams

    Title:
    President and Chief Executive Officer

United States securities and exchange commission logo
April 14, 2022
Eric A. Adams
Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310 – 815 West Hastings Street
Vancouver, British Columbia V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-3
Filed April 7, 2022
File No. 333-264187
Dear Mr. Adams:
            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 or Christine Westbrook at 202-551-
5019 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Brian P. Fenske, Esq.

CORRESP
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February 10, 2022

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

    Re:

    InMed Pharmaceuticals Inc.

    Registration Statement on Form S-3

    Filed February 4, 2022

    Amended February 9, 2022

    File No. 333-262532

Ladies and Gentlemen:

On behalf of InMed Pharmaceuticals Inc., a British
Columbia corporation (the “Company”), the undersigned hereby respectfully submits its request for acceleration
of effectiveness. Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that
the effective date of the above referenced Registration Statement on Form S-3, as amended (the “Registration Statement”),
be accelerated so that the same will become effective at 4:00 p.m., Washington, D.C. time, on Friday, February 11, 2022, or as soon as
practicable thereafter.

Please notify Brian P. Fenske of Norton Rose Fulbright
US LLP, counsel to the Company, at (713) 651-5557, as soon as the Registration Statement has been declared effective, or if you have any
other questions or concerns regarding this matter.

    Very truly yours,

    InMed Pharmaceuticals Inc.

    By:
    /s/ Eric A. Adams

    Name:
    Eric A. Adams

    Title:
    President and Chief Executive Officer

CORRESP
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February 9, 2022

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

    Re:

    InMed Pharmaceuticals Inc.

    Registration Statement on Form S-3

    Filed February 4, 2022

    File No. 333-262533

Ladies and Gentlemen:

On behalf of InMed Pharmaceuticals Inc., a British
Columbia corporation (the “Company”), the undersigned hereby respectfully submits its request for acceleration
of effectiveness. Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that
the effective date of the above referenced Registration Statement on Form S-3 (the “Registration Statement”),
be accelerated so that the same will become effective at 4:00 p.m., Washington, D.C. time, on Friday, February 11, 2022, or as soon as
practicable thereafter.

Please notify Brian P. Fenske of Norton Rose Fulbright
US LLP, counsel to the Company, at (713) 651-5557, as soon as the Registration Statement has been declared effective, or if you have any
other questions or concerns regarding this matter.

    Very truly yours,

    InMed Pharmaceuticals Inc.

    By:
    /s/ Eric A. Adams

    Name:
    Eric A. Adams

    Title:
    President and Chief Executive Officer

United States securities and exchange commission logo
February 8, 2022
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310 – 815 West Hastings Street
Vancouver, British Columbia V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-3
Filed February 4, 2022
File No. 333-262533
Dear Mr. Adams:
            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 Gary Guttenberg at (202) 551-6477 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Brian Fenske

United States securities and exchange commission logo
July 19, 2021
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
815 W. Hastings Street, Suite 310
Vancouver, B.C. V6C 1B4
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed July 13, 2021
File No. 333-257858
Dear Mr. Adams:
            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:       Brian Fenske

CORRESP
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July 19, 2021

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

    Re:

    InMed Pharmaceuticals Inc.

    Registration Statement on Form S-1

    Filed July 13, 2021

    File No. 333-257858

Ladies and Gentlemen:

On behalf of InMed Pharmaceuticals Inc., a British
Columbia corporation (the “Company”), the undersigned hereby respectfully requests the withdrawal of a previously
filed letter to the SEC (Accession Number: 0001213900-21-037519) and hereby resubmits its request for acceleration of effectiveness. Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that the effective date of the above
referenced Registration Statement on Form S-1 (the “Registration Statement”), be accelerated so that the same
will become effective at 9:00 a.m., Washington, D.C. time, on Thursday, July 22, 2021, or as soon as practicable thereafter.

Please notify Brian P. Fenske of Norton Rose Fulbright
US LLP, counsel to the Company, at (713) 651-5557, as soon as the Registration Statement has been declared effective, or if you have any
other questions or concerns regarding this matter.

    Very truly yours,

    InMed Pharmaceuticals Inc.

    By:
    /s/ Eric A. Adams

    Name:
    Eric A. Adams

    Title:
    President and Chief Executive Officer

CORRESP
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July
19, 2021

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

    Re:
    InMed
                                            Pharmaceuticals Inc.

    Registration
    Statement on Form S-1

    Filed
    July 13, 2021

    File
    No. 333-257858

Ladies
and Gentlemen:

On
behalf of InMed Pharmaceuticals Inc., a British Columbia corporation (the “Company”), and pursuant to Rule
461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that the effective date of the above referenced
Registration Statement on Form S-1 (the “Registration Statement”), be accelerated so that the same will become
effective at 8:00 a.m., Washington, D.C. time, on Thursday, July 22, 2021, or as soon as practicable thereafter.

Please
notify Brian P. Fenske of Norton Rose Fulbright US LLP, counsel to the Company, at (713) 651-5557, as soon as the Registration Statement
has been declared effective, or if you have any other questions or concerns regarding this matter.

    Very
    truly yours,

    InMed
    Pharmaceuticals Inc.

    By:
    /s/
    Eric A. Adams

    Name:
    Eric
    A. Adams

    Title:
    President
    and Chief Executive Officer

CORRESP
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March 11, 2021

Via
EDGAR

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549-7010 USA

Re:  InMed Pharmaceuticals Inc.

    Registration Statement on Form S-1

    Filed March 5, 2021

    File No. 333-253925

Pursuant to Rule 461(a) under the Securities
Act of 1933, as amended (the “Securities Act”), InMed Pharmaceuticals Inc. (the “Company”) hereby respectfully
requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced
Registration Statement (the “Registration Statement”) to March 15, 2021 at 5:00 p.m. (Eastern) or as soon thereafter
as is practicable.

The Company also requests the Commission
confirm the effective date and time of the Registration Statement in writing.

    INMED PHARMACEUTICALS INC.

    By:
    /s/ Bruce Colwill

    Name:	Bruce Colwill
Title: Chief
Financial Officer

InMed
Pharmaceuticals Inc, #310-815 West Hastings St., Vancouver, BC, Canada, V6C-1B4

www.inmedpharma.com
Tel. 604.669.7207 Fax. 778.945.6800

United States securities and exchange commission logo
March 10, 2021
Eric Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310 - 815 W. Hastings Street, Vancouver, B.C.
V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed March 5, 2021
File No. 333-253925
Dear Mr. Adams:
            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 Kasey Robinson at 202-551-5880 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel Miller

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CORRESP

 Roth Capital Partners, LLC

888 San Clemente Drive

Newport Beach, CA 92660

 November 10,
2020

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

Re:
 InMed Pharmaceuticals Inc. (the “Company”)

Registration Statement on Form S-1 (File No. 333-239319)

 Ladies and Gentlemen:

In connection with the above-captioned registration statement, and pursuant to Rule 461 under the Securities Act of 1933, as
amended (the “Act”), Roth Capital Partners, LLC, as the representative of the underwriters, hereby joins in the request of the Company that the effective date of such registration statement be accelerated to 9:00 a.m. (Eastern time) on
Thursday, November 12, 2020, or as soon thereafter as practicable.

 In making this request the undersigned
acknowledges that it is aware of its obligations under the Act as they relate to the public offering of securities pursuant to the registration statement.

[Signature Page Follows]

 Very truly yours,

 ROTH CAPITAL PARTNERS, LLC,

 As
the Representative of the Underwriters

By:

/s/ Aaron M. Gurewitz

Name:

Aaron M. Gurewitz

Title:

Head of Equity Capital Markets

CORRESP
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CORRESP

 InMed Pharmaceuticals, Inc.

Suite #310-815 W. Hastings St.

Vancouver, BC V6C 1B4

Canada

 November 10, 2020

VIA EDGAR

 Securities and Exchange Commission

 100 F Street N.E.

 Washington, D.C. 20549-7010

USA

Re:
 InMed Pharmaceuticals Inc.

Registration Statement on Form S-1

Filed June 19, 2020, as amended

File No. 333-239319

Reference is made to the letter dated November 5, 2020, pursuant to which InMed Pharmaceuticals Inc. (the “Company”) requested
that the effective date of the above-referenced Registration Statement be accelerated to November 9, 2020 at 5:00 p.m. (Eastern), which date was subsequently revised to November 10, 2020 (the “Acceleration Request”).

The Company hereby withdraws the Acceleration Request, and respectfully requests that such Registration Statement not become effective at the
date and time set forth in the Acceleration Request.

INMED PHARMACEUTICALS INC.

By

/s/ Eric A. Adams

 Name:  Eric A. Adams

Title:   President & Chief Executive Officer

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CORRESP

 [LETTERHEAD OF INMED PHARMACEUTICALS INC.]

November 10, 2020

 VIA EDGAR

 Securities and Exchange Commission

 100 F Street N.E.

 Washington, D.C. 20549-7010

USA

Re:
 InMed Pharmaceuticals Inc.

 Registration Statement on Form S-1

Filed June 19, 2020, as amended

 File No. 333-239319

 Pursuant
to Rule 461(a) under the Securities Act of 1933, as amended (the “Securities Act”), InMed Pharmaceuticals Inc. (the “Company”) hereby respectfully requests that the Securities and Exchange Commission (the “Commission”)
accelerate the effective date of the above-referenced Registration Statement (the “Registration Statement”) to November 12, 2020 at 9:00 a.m. (Eastern) or as soon thereafter as is practicable.

The Company also requests the Commission confirm the effective date and time of the Registration Statement in writing.

INMED PHARMACEUTICALS INC.

By

/s/ Eric A. Adams

 Name: Eric A. Adams

 Title:
  President & Chief Executive Officer

CORRESP
1
filename1.htm

CORRESP

 November 5, 2020

VIA EDGAR

 Securities and Exchange Commission

 100 F Street N.E.

 Washington, D.C.
20549-7010

 USA

Re:
 InMed Pharmaceuticals Inc.

Registration Statement on Form S-1

Filed June 19, 2020, as amended

File No. 333-239319

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended (the “Securities Act”), InMed
Pharmaceuticals Inc. (the “Company”) hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement (the
“Registration Statement”) to November 9, 2020 at 5:00 p.m. (Eastern) or as soon thereafter as is practicable.

The Company also requests the Commission confirm the effective date and time of the Registration Statement in writing.

INMED PHARMACEUTICALS INC.

By

 /s/ Eric A. Adams

 Name:   Eric A. Adams

 Title:   President & Chief Executive Officer

InMed Pharmaceuticals Inc, #310-815 West Hastings St., Vancouver, BC,
Canada, V6C-1B4

www.inmedpharma.com    Tel. 604.669.7207    Fax.
778.945.6800

CORRESP
1
filename1.htm

CORRESP

 Roth Capital Partners, LLC

888 San Clemente Drive

Newport Beach, CA 92660

 November 5,
2020

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 InMed Pharmaceuticals Inc. (the “Company”)

Registration Statement on Form S-1 (File No. 333-239319)

 Ladies and Gentlemen:

In connection with the above-captioned registration statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the
“Act”), Roth Capital Partners, LLC, as the representative of the underwriters, hereby joins in the request of the Company that the effective date of such registration statement be accelerated to 5:00 p.m. (Eastern time) on Monday,
November 9, 2020, or as soon thereafter as practicable.

 In making this request the undersigned acknowledges that it is aware of its
obligations under the Act as they relate to the public offering of securities pursuant to the registration statement.

 [Signature Page
Follows]

 Very truly yours,

ROTH CAPITAL PARTNERS, LLC,

As the Representative of the Underwriters

By:

/s/ Aaron M. Gurewitz

Name:

Aaron M. Gurewitz

Title:

Head of Equity Capital Markets

United States securities and exchange commission logo
October 14, 2020
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310-815 W. Hastings Street
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Amendment No. 4 to Registration Statement on Form S-1
Filed October 8, 2020
File No. 333-239319
Dear Mr. Adams:
            We have reviewed your amended registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 4 to Registration Statement on Form S-1 filed October 8, 2020
Exhibits
1.Please have counsel file a revised Exhibit 5.1 opinion that includes the opinion that the
warrants will be binding obligations of the company. For guidance, refer to Section
II.B.1.f of Staff Legal Bulletin No. 19.

 FirstName LastNameEric A. Adams
 Comapany NameInMed Pharmaceuticals Inc.
 October 14, 2020 Page 2
 FirstName LastName
Eric A. Adams
InMed Pharmaceuticals Inc.
October 14, 2020
Page 2
            You may contact Ibolya Ignat at 202-551-3636 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel M. Miller, Esq.

CORRESP
1
filename1.htm

CORRESP

DANIEL M. MILLER

Partner

(604) 630-5199

FAX (604) 687-8504

miller.dan@dorsey.com

 October 8, 2020

 Division
of Corporation Finance

 U.S. Securities and Exchange Commission

100 F Street N.E.

 Washington, D.C. 20549

USA

 Attention: Division of Corporation Finance, Office of Life
Sciences

Re:
 InMed Pharmaceuticals Inc.

Amendment No. 3 to Registration Statement on Form S-1

Filed September 15, 2020

CIK No. 0001728328

 Dear Sirs and
Mesdames:

 On behalf of our client, InMed Pharmaceuticals Inc. (the “Company”), and pursuant to the Securities Act of 1933, as amended (the
“Act”), and the rules and regulations thereunder, we transmit for your review the Company’s responses, as we have been informed by the Company, to the comment included in the Staff’s letter of comments, dated September 22,
2020 (the “Comment”), in respect of the above noted registration statement submission. The Company’s response below is keyed to the Comment.

Amendment No. 3 to the Registration Statement on Form S-1 filed September 15, 2020

Prospectus Summary

 Overview, page 2

1.
 We note your disclosure on page 4 that to date you have safety data with
INM-755 in 22 healthy adult volunteers and that a regulatory application was approved on April 17, 2020 for a second Phase 1 clinical trial in healthy volunteers. Please revise your pipeline table and
your Risk Factor on page 29 to make it clear that your clinical development to date has been conducted outside the U.S.

The requested revisions have been made on page 29 of the Registration Statement under the heading “Risk Factors”, and in the tables
on page 3 and page 67 of the Registration Statement.

U.S. Securities and Exchange Commission

October 8, 2020

Page 2

 Should you have further comments or require further information, or if any questions should arise in connection with this
submission, please call the undersigned at (604) 630-5199. You also may email me at miller.dan@dorsey.com or fax me at (604) 687-8504.

Yours truly,

/s/ Daniel M. Miller

Daniel M. Miller

cc:
 Eric A. Adams

Bruce S. Colwill

        InMed Pharmaceuticals Inc.

United States securities and exchange commission logo
September 22, 2020
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310-815 W. Hastings Street
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed September 15, 2020
File No. 333-239319
Dear Mr. Adams:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.
Amendment No. 3 to Registration Statement on Form S-1 filed September 15, 2020
Prospectus Summary
Overview, page 2
1.We note your disclosure on page 4 that to date you have safety data with INM-755 in 22
healthy adult volunteers and that a regulatory application was approved on April 17, 2020
for a second Phase 1 clinical trial in healthy volunteers. Please revise your pipeline table
and your Risk Factor on page 29 to make it clear that your clinical development to date
has been conducted outside the U.S.

 FirstName LastNameEric A. Adams
 Comapany NameInMed Pharmaceuticals Inc.
 September 22, 2020 Page 2
 FirstName LastName
Eric A. Adams
InMed Pharmaceuticals Inc.
September 22, 2020
Page 2
            You may contact Ibolya Ignat at 202-551-3636 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel M. Miller, Esq.

CORRESP
1
filename1.htm

CORRESP

 DANIEL M. MILLER

 Partner

(604) 630-5199

FAX (604) 687-8504

miller.dan@dorsey.com

 September 14, 2020

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street N.E.

 Washington, D.C. 20549

USA

Attention:
 Division of Corporation Finance, Office of

Life Sciences

Re:
 InMed Pharmaceuticals Inc.

Amendment No. 2 to Draft Registration Statement on Form S-1

Submitted July 21, 2020

CIK No. 0001728328

 Dear Sirs and
Mesdames:

 On behalf of our client, InMed Pharmaceuticals Inc. (the “Company”), and pursuant to the Securities Act of 1933, as amended (the
“Act”), and the rules and regulations thereunder, we transmit for your review the Company’s responses, as we have been informed by the Company, to the Staff’s comments delivered orally on August 3, 2020 (the
“Comments”), in respect of the above noted registration statement submission. The Company’s responses below are keyed to the Comments.

1.
 Please revise your disclosure to include the estimated amount of proceeds you plan to allocate for each of
the uses identified. If you have specific purposes in mind for the use of proceeds, you must disclose the estimated net amount of the proceeds broken down into each principal intended use. This is required even if management will have broad
discretion in allocating the proceeds. See Item 504 of Regulation S-K.

 The
fourth paragraph under the Section entitled “Use of Proceeds” has been replaced with the following disclosure:

“The principal purposes of this offering are to obtain additional capital to support our operations and to facilitate our
planned Nasdaq listing. We intend to use the net proceeds from this offering for the following purposes:

•

 approximately $6 million in the aggregate to fund our development efforts of
INM-755 including a Phase I/II clinical trial;

 U.S. Securities and Exchange Commission

September 14, 2020

  Page
 2

•

 approximately $2 million in the aggregate to fund our ongoing development efforts of INM-088;

•

 approximately $1 million in the aggregate to fund the general development efforts of our IntegraSyn™ program; and

•

 the approximately remaining $2 million to fund other research and development and general corporate
purposes.

 We may also use a portion of the remaining net proceeds to
in-license, acquire, or invest in complementary businesses, intellectual property, products or assets. However, we have no current commitments or obligations to do so.”

2.
 We note your response to Comment two. The investor presentation did not appear to fit within any available
safe harbors for communications provided by the rules under the Securities Act of 1933. We also reference counsel’s telephone call to the Staff on July 22, in which counsel indicated your Amendment No. 2 to the Form S-1 and draft registration statement was distributed to approximately 7,000 email addresses. Please revise to add risk factor disclosure addressing the potential Section 5 liability. Disclose that investors may
have claims against the company and may be entitled to rescission rights or damages. In addition, please tell us how you consider the need to accrue or disclose a contingent liability in accordance with ASC topic
450-20 and the basis for your conclusion.

 The requested risk factor has
been included in the “Risk Factors” section of Amendment No. 3 to the Registration Statement on Form S-1.

The Company acknowledges the Staff’s comment relating to considering the need to accrue or disclose a potential contingent liability
related to a potential violation of Section 5 of the Securities Act in accordance with ASC topic 450-20. Under ASC 450-20-25-2, an estimated loss from a loss contingency shall be accrued by a charge to income if both of the following conditions are met:

a. Information available prior to issuance of the financial statements indicates that it is probable that an asset had been impaired or a
liability had been incurred at the date of the financial statements. Date of the financial statements means the end of the most recent accounting period for which financial statements are being presented. It is implicit in this condition that it
must be probable that one or more future events will occur confirming the fact of the loss; and

 b. The amount of loss can be reasonably
estimated.

 U.S. Securities and Exchange Commission

September 14, 2020

  Page
 3

 As the inadvertent
disclosures occurred subsequent to the end of the most recent accounting period, an accrual under ASC 450-20 is not permitted. However, based on the available information the Company believes that even if an
accrual were permitted, the possibility of an assertion of such a claim is not probable and thus would not have met the criteria for accrual even if the inadvertent disclosures had occurred prior to the end of the most recent accounting period.

The Company has inserted the following disclosure in the Management Discussion and Analysis of Financial Condition and Results of Operations
section of Amendment No. 3 to the Registration Statement on Form S-1 and in the contingency section of the Company’s annual Audited Consolidated Financial Statements for the year ended June 30,
2020 included in Amendment No. 3 to the Registration Statement on Form S-1.

 “In July
2020, in connection with a proposed public offering of our common shares, two inadvertent disclosures of already publicly available information were made that may have exceeded the scope permissible under Rule 134 of the Securities Act of 1933, and
thus may not be entitled to the “safe-harbor” provided by Rule 134. As a result, either of the two inadvertent disclosures could be determined to not be in compliance for a registered securities offering under Section 5 of the
Securities Act of 1933. If either of the two inadvertent disclosures are determined by a court to be a violation by the Company of the Securities Act of 1933, the recipients of the inadvertent disclosures who purchase our common shares in the
Company’s planned offering may have a rescission right, which could require the Company to repurchase those shares at their original purchase price with interest or a claim for damages if the purchaser no longer owns the securities, for one
year following the date of the possible violation. The Company could also incur considerable expenses if it were to contest any such claims. Consequently, a contingent liability may arise out of this possible violation of the Securities Act of 1933.
The likelihood and magnitude of this potential contingent liability, if any, is not determinable at this time.”

 Additional Information

On August 15, 2020, the Company became required to update its annual audited consolidated financial statements included in its Registration Statement on
Form S-1. As a result, the Amendment No. 3 to the Registration Statement on Form S-1 also includes updated annual consolidated financial statements and a
corresponding Management’s Discussion and Analysis of Financial Condition and Results of Operations, as well as other conforming changes related thereto.

*            *
 *

 U.S. Securities and Exchange Commission

September 14, 2020

  Page
 4

 Should you have further comments or
require further information, or if any questions should arise in connection with this submission, please call the undersigned at (604) 630-5199. You also may email me at miller.dan@dorsey.com or fax me
at (604) 687-8504.

Yours truly,

/s/ Daniel M. Miller

Daniel M. Miller

cc:
 Eric A. Adams

Bruce S. Colwill

 InMed
Pharmaceuticals Inc.

CORRESP
1
filename1.htm

CORRESP

 DANIEL M. MILLER

Partner

 (604) 630-5199

 FAX (604) 687-8504

miller.dan@dorsey.com

July 21, 2020

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F Street N.E.

Washington, D.C. 20549

 USA

Attention:
 Division of Corporation Finance, Office of

Life Sciences

Re:
 InMed Pharmaceuticals Inc.

Amendment No. 1 to Registration Statement on Form S-1

Submitted July 6, 2020

CIK No. 0001728328

 Dear Sirs and
Mesdames:

 On behalf of our client, InMed Pharmaceuticals Inc. (the “Company”), and pursuant to the Securities Act of 1933, as amended (the
“Act”), and the rules and regulations thereunder, we transmit for your review the Company’s response, as we have been informed by the Company, to one of the comments included in the Staff’s letter of comment, dated July 14,
2020 (the “Comment Letter”), in respect of the above noted registration statement. The Company’s response below is keyed to the heading and comment number contained in the Comment Letter.

Amendment No. 1 to Registration Statement on Form S-1 filed on July 6, 2020

About this Prospectus and Exchange Rates, page 1

1.
 You disclose that on June 30, 2020 you have effected a share consolidation (the “June 30, 2020
Share Consolidation”), pursuant to which your issued and outstanding common shares have been consolidated at a ratio of one post-consolidation common share for every 33 pre-consolidation common share.
Certain information throughout your document, as noted, and your financial statements, and the related notes have not been adjusted to give effect to the June 30, 2020 Share Consolidation. Please revise all financial information, and all
financial statements to reflect the share consolidation in accordance with ASC 260-10-55-12 and SAB Topic 4C, or tell us why such
revision is not required. If you conclude that a revision is necessary, please have your independent auditor revise its report on page F-3 to reference the share consolidation, and dual-date its opinion in
accordance with AICPA AU-C Section 560.A11. The requested revisions have been made within Amendment No. 2 to the registration statement and to the financial statements and the related notes included
therein, in order to, in accordance with ASC 260 and SAB Topic 4C, give effect to the June 30, 2020 Share Consolidation. In addition, the Company’s auditors have revised their opinion to dual-date it in accordance with AICPA AU-C Section 560.A11.

 U.S. Securities and Exchange Commission

July 21, 2020

 Page 2

 The requested revisions have been made within Amendment No. 2 to the registration statement
and to the financial statements and the related notes included therein, in order to, in accordance with ASC 260 and SAB Topic 4C, give effect to the June 30, 2020 Share Consolidation. In addition, the Company’s auditors have revised their
opinion to dual-date it in accordance with AICPA AU-C Section 560.A11.

*        *        *

Should you have further comments or require further information, or if any questions should arise in connection with this submission, please call the
undersigned at (604) 630-5199. You also may email me at miller.dan@dorsey.com or fax me at (604) 687-8504.

Yours truly,

/s/ Daniel M. Miller

Daniel M. Miller

cc:
 Eric A. Adams

Bruce S. Colwill

        InMed Pharmaceuticals Inc.

CORRESP
1
filename1.htm

CORRESP

 DANIEL M. MILLER

 Partner

(604) 630-5199

FAX (604) 687-8504

miller.dan@dorsey.com

July 20, 2020

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F Street N.E.

Washington, D.C. 20549

 USA

Attention: Division of Corporation Finance, Office of Life Sciences

Re:
 InMed Pharmaceuticals Inc.

Amendment No. 1 to Registration Statement on Form S-1

Submitted July 6, 2020

CIK No. 0001728328

Dear Sirs and Mesdames:

 On behalf of our client, InMed
Pharmaceuticals Inc. (the “Company”), and pursuant to the Securities Act of 1933, as amended (the “Act”), and the rules and regulations thereunder, we transmit for your review the Company’s response, as we have been informed
by the Company, to one of the comments included in the Staff’s letter of comment, dated July 14, 2020 (the “Comment Letter”), in respect of the above noted registration statement. The Company’s response below is keyed to the
heading and comment number contained in the Comment Letter.

 Amendment No. 1 to Registration Statement on
Form S-1 filed on July 6, 2020

 General

2.
 We note that you made available an investor presentation dated July 2020 available on your website. Please
tell us why this presentation is consistent with Section 5 of the Securities Act, including any applicable safe harbor rules. We may have further comments upon review of your response.

As a company that has been publicly traded in Canada for many years, and currently has its common shares trading on the Toronto Stock
Exchange, like many other public companies, the Company maintains a publicly accessible corporate presentation on its website. Historically, the Company has called such presentation an “Investor Presentation”. In July 2020, the Company
updated its Investor Presentation in order to reflect certain developments in the Company’s business that had separately been disclosed publicly by the Company.

 U.S. Securities and Exchange Commission

July 20, 2020

 Page 2

The Company prepared two versions of the revised Investor Presentation, one to be used on its website and in any “Test-The-Waters” meetings, and one to eventually be used as part of a road show for the Company’s proposed public offering. The only difference between the two
versions of the presentation is that the version intended for use as part of the road show includes a disclaimer that references the filling of the Registration Statement.

Inadvertently, the Company posted the wrong version of the Investor Presentation on its website. Promptly after becoming aware of the error,
the Company replaced the incorrect version on its website with the version that does not reference the Registration Statement. In addition, the Company changed the name of the version on its website to “Company Presentation”.

To date, the Company has not engaged in any road show or other marketing of the transaction, and neither the Company nor the underwriters for
the offering have received any inquiries from potential investors who became aware of the offering based upon reviewing the website presentation.

* * *

 Should you have further comments or
require further information, or if any questions should arise in connection with this submission, please call the undersigned at (604) 630-5199. You also may email me at miller.dan@dorsey.com or fax me
at (604) 687-8504.

Yours truly,

/s/ Daniel M. Miller

Daniel M. Miller

 cc:

 Eric A. Adams

 Bruce S. Colwill

 InMed Pharmaceuticals Inc.

United States securities and exchange commission logo
July 14, 2020
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310-815 W. Hastings Street
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 6, 2020
File No. 333-239319
Dear Mr. Adams:
            We have reviewed your amended 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1 filed July 6, 2020
About this Prospectus and Exchange Rates, page 1
1.You disclose that on June 30, 2020 you have effected a share consolidation (the “June 30,
2020 Share Consolidation”), pursuant to which your issued and outstanding common
shares have been consolidated at a ratio of one post-consolidation common share for every
33 pre-consolidation common share. Certain information throughout your document, as
noted, and your financial statements, and the related notes have not been adjusted to give
effect to the June 30, 2020 Share Consolidation.  Please revise all financial information,
and all financial statements to reflect the share consolidation in accordance with ASC 260-
10-55-12 and SAB Topic 4C, or tell us why such revision is not required.  If you conclude
that a revision is necessary, please have your independent auditor revise its report on page

 FirstName LastNameEric A. Adams
 Comapany NameInMed Pharmaceuticals Inc.
 July 14, 2020 Page 2
 FirstName LastName
Eric A. Adams
InMed Pharmaceuticals Inc.
July 14, 2020
Page 2
F-3 to reference the share consolidation, and dual-date its opinion in accordance with
AICPA AU-C Section 560.A11.
General
2.We note that you have made available an investor presentation dated July 2020 on your
website.  Please tell us why this presentation is consistent with Section 5 of the Securities
Act, including any applicable safe harbor rules.  We may have further comments upon
review of your response.
            You may contact Ibolya Ignat at 202-551-3636 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel M. Miller, Esq.

CORRESP
1
filename1.htm

CORRESP

 DANIEL M. MILLER

 Partner

(604) 630-5199

FAX (604) 687-8504

miller.dan@dorsey.com

 July 6, 2020

 Division of
Corporation Finance

 U.S. Securities and Exchange Commission

100 F Street N.E.

 Washington, D.C. 20549

USA

 Attention: Division of Corporation Finance, Office of Life
Sciences

Re:
 InMed Pharmaceuticals Inc.

Amendment No. 1 to Registration Statement on Form S-1

Submitted June 19, 2020

CIK No. 0001728328

 Dear Sirs and
Mesdames:

 On behalf of our client, InMed Pharmaceuticals Inc. (the “Company”), and pursuant to the Securities Act of 1933, as amended (the
“Act”), and the rules and regulations thereunder, we transmit for your review the Company’s responses, as we have been informed by the Company, to the Staff’s letter of comment, dated June 26, 2020 (the “Comment
Letter”), in respect of the above noted registration statement. The Company’s response below is keyed to the heading and comment number contained in the Comment Letter.

Registration Statement on Form S-1 filed on June 19, 2020

Business

 Our Product Candidates and
Technologies

 Key Milestones, page 79

1.
 We note your response to comment 3. It appears that your Collaborative Research Agreement with the
University of British Columbia is material to your business. Please disclose in the Summary section that such agreement may be terminated by either party upon 30 days’ written notice, as referenced on page 78.

The requested revisions have been made in the noted section, as well as to a related risk factor in the section entitled “Risk
Factors”, of Amendment No. 1 to the Registration Statement on Form S-1.

 DORSEY & WHITNEY
LLP · WWW.DORSEY.COM · T  604.687.5151 · F  604.687.8504

 SUITE 1605 · 777 DUNSMUIR STREET
· P.O. BOX 10444 · PACIFIC CENTRE · VANCOUVER, BRITISH COLUMBIA CANADA V7Y 1K4

USA    CANADA    EUROPE    ASIA

 U.S. Securities and Exchange Commission

July 6, 2020

  Page
 2

 The Company has also made additional revisions in Amendment No. 1 to the Registration
Statement on Form S-1, in order to reflect the Company’s recently completed share consolidation and certain other matters.

*            *
 *

 Should you have further comments or require further information, or if any questions should arise in connection with this submission, please call
the undersigned at (604) 630-5199. You also may email me at miller.dan@dorsey.com or fax me at (604) 687-8504.

Yours truly,

/s/ Daniel M. Miller

Daniel M. Miller

cc:
 Eric A. Adams

Bruce S. Colwill

 InMed
Pharmaceuticals Inc.

 DORSEY & WHITNEY LLP

United States securities and exchange commission logo
June 26, 2020
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310-815 W. Hastings Street
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Registration Statement on Form S-1
Filed June 19, 2020
File No. 333-239319
Dear Mr. Adams:
            We have reviewed your registration statement and have the following comment.  In our
comment, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to the comment, we may have additional comments.
Registration Statement on Form S-1 filed on June 19, 2020
Business
Our Product Candidates and Technologies
Key Milestones, page 79
1.We note your response to comment 3. It appears that your Collaborative Research
Agreement with the University of British Columbia is material to your business. Please
disclose in the Summary section that such agreement may be terminated by either party
upon 30 calendar days' written notice, as referenced on page 79.

 FirstName LastNameEric A. Adams
 Comapany NameInMed Pharmaceuticals Inc.
 June 26, 2020 Page 2
 FirstName LastName
Eric A. Adams
InMed Pharmaceuticals Inc.
June 26, 2020
Page 2
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Ibolya Ignat at 202-551-3636 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel M. Miller, Esq.

United States securities and exchange commission logo
June 10, 2020
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310-815 W. Hastings Street
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted May 27, 2020
CIK No. 0001728328
Dear Mr. Adams:
            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 27, 2020
Prospectus Summary
Overview, page 2
1.We note your response to comment 2. The prospectus summary should provide a brief,
but balanced, description of the key aspects of your business.  Please balance your
statement that your approach leverages the history of health benefits attributed to the
cannabis plant with disclosure in this "Overview" section that the U.S. Food and Drug
Administration (FDA) has, to date, not approved any marketing application for cannabis
for the treatment of any disease or condition and has approved only one cannabis-derived
and three cannabis-related drug products. Additionally, we note your response to comment

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 FirstName LastNameEric A. Adams
InMed Pharmaceuticals Inc.
June 10, 2020
Page 2
3, which we reissue. Please provide a discussion of the risks and challenges you face in
implementing your business plan that is dependent on your biosynthesis-based
manufacturing system, e.g. the need to scale up manufacturing capacity from current
limited levels, as discussed on page 42.
INM-755 in Dermatology, page 4
2.We note your response to comment 8 and your revised disclosure stating that “[a]s
assessed by the Netherlands National Competent Authority and Ethics Committee, the
findings from our toxicology studies supported the safety of CBN for Phase I clinical
development studies in healthy volunteers.”  Safety is assessed throughout all phases of
clinical trials.  As your product candidates have not completed clinical trials, your product
candidates have not been determined to be safe.  Therefore, it is inappropriate to state or
imply that your product candidates will be determined to be safe. Please revise your
disclosure to remove such implication here and throughout your registration
statement. We will not object to statements that your product candidate was well-
tolerated. Additionally, please revise your disclosure to clarify, if true, that the disclosure
in the third paragraph of this section relates to your Phase 1 study (755-101-HV)
discussed in the paragraph above.
Business
Our Product Candidates and Technologies
Key Milestones, page 78
3.We note your response to comment 12.  Please further revise your description of the
Collaborative Research Agreements and Technology Assignment Agreements with
the University of British Columbia to disclose the termination provisions and the term of
your royalty obligations, respectively.
INM-088 for the Treatment of Glaucoma, page 100
4.We note your response to comment 16. Please revise your characterization of the INM-
088 preclinical trials to discuss the actual data from the preclinical trials, rather than
drawing conclusions from the results. As illustrative examples only, we note the following
disclosures:

•CBN has a significant anti-apoptotic effect on differentiated RGCs when subjected to
elevated hydrostatic pressure.....Exposure of these cells under the same conditions
concurrently with CBN prevented apoptosis and resulted in a significantly higher
level of cell survival.
•reduction in IOP and improvement of pERG amplitudes were used to demonstrate
effectiveness of CBN as a potential glaucoma treatment.

 FirstName LastNameEric A. Adams
 Comapany NameInMed Pharmaceuticals Inc.
 June 10, 2020 Page 3
 FirstName LastName
Eric A. Adams
InMed Pharmaceuticals Inc.
June 10, 2020
Page 3

Intellectual Property , page 110
5.We note your response to comment 17.  Please revise to identify the material jurisdictions
where patent applications are pending. Please also provide estimated expiry dates if the
applications are approved.
            You may contact Ibolya Ignat at 202-551-3636 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel M. Miller, Esq.

United States securities and exchange commission logo
May 11, 2020
Eric A. Adams
President and Chief Executive Officer
InMed Pharmaceuticals Inc.
Suite 310-815 W. Hastings Street
Vancouver, B.C. V6C 1B4
Canada
Re:InMed Pharmaceuticals Inc.
Draft Registration Statement on Form S-1
Submitted April 13, 2020
CIK No. 0001728328
Dear Mr. Adams:
            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 13, 2020
Cover page
1.We note your disclosure that you have applied to list your common shares on the Nasdaq
Capital Market and on page 12 that there can be no assurance that Nasdaq will approve
your listing application. Please clarify whether the offering is contingent upon receiving
Nasdaq listing approval, and if it is not, please revise your disclosure to clarify this fact.

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 May 11, 2020 Page 2
 FirstName LastNameEric A. Adams
InMed Pharmaceuticals Inc.
May 11, 2020
Page 2
Prospectus Summary
Overview, page 2
2.We note your disclosure that your approach leverages on the history of health benefits
attributed to the cannabis plant and applies tried, tested and true pharmaceutical drug
development discipline to establish individual cannabinoid compounds as clinically-
proven, FDA-approved medicines. Please place your disclosure in appropriate context by
disclosing that the U.S. Food and Drug Administration (FDA) has, to date, not approved
any marketing application for cannabis for the treatment of any disease or condition and
has approved only one cannabis-derived and three cannabis-related drug products.
Additionally, please revise your disclosure to remove any implication that you are
presently successful or are likely to be successful in securing marketing approval for any
of your product candidates.  Please make similar revisions to your statement on page 6
that you have the internal capabilities to design and execute, together with multiple
external vendors, the preclinical data sets and clinical studies required to advance
pharmaceutical drugs towards FDA approval and, ultimately, commercialization.
3.We note your disclosure that you are developing a proprietary biosynthesis manufacturing
technology to facilitate access to rare cannabinoids that are otherwise not available at
commercial scale and low cost. Please balance this disclosure with a discussion of the
risks and challenges you face in manufacturing pharmaceutical-grade cannabinoids, such
as the need to scale up manufacturing capacity from current limited levels, as discussed on
page 42.
4.We refer to your development programs table on pages 3 and 67. You may describe the
results of preclinical studies in your narrative disclosure with full and proper context with
respect to the objective observations of such studies; however, it is inappropriate to
present preclinical studies as establishing proof-of-concept for your product candidates.
Please remove this text from the table. We also note your inclusion of “Additional Uses of
Rare Cannabinoids." Please revise your table to identify the specific product candidates
and indications.  If you have not yet identified specific product candidates or the
indications which they will treat, please remove reference to such programs from your
table as such information is premature for inclusion in your Summary presentation.
Similarly, please revise your table to identify dermatology indication #2 and ocular
indication #2.
5.We refer to your development programs table on pages 3 and 67.  Please include a column
for each of Phase 1, Phase 2 and Phase 3. Additionally, please revise your clinical
development table on pg. 95 to make it clear that you will need to complete Phase 3
clinical trials.

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 May 11, 2020 Page 3
 FirstName LastNameEric A. Adams
InMed Pharmaceuticals Inc.
May 11, 2020
Page 3
6.We note your statement on page 3 that you have "no relationship with the Cannabis
plant."  However, your risk factor disclosure on page 28 indicates that your product
candidates contain substances related to the Cannabis plant and may therefore be
classified as “controlled substances” and that their regulatory approval may generate
public controversy.  Please reconcile your disclosure.
7.We note your statements on pages 4 and 69 that "THC and CBD have established
therapeutic benefits in certain instances." Given that it is within the sole authority of the
FDA or similar foreign regulator to determine the efficacy of a drug and that efficacy is
determined by reference to the indication being treated, the statement THC and CBD have
established therapeutic benefits in certain instances is not appropriate. Please delete these
statements. You may replace these statements with a description of a publicly available
clinical trial conducted to assess efficacy and the resulting data. The accompanying
disclosures should identify the party performing the trial and include the number of
participants and dosing information but should not draw conclusions about efficacy from
the data. Additionally, we note your disclosure that you have completed more than 30
pharmacology and toxicology studies to investigate the effects of CBN. Please place this
selected disclosure in its proper context by revising your Summary disclosure to make it
clear that your clinical data to date is limited to a small number of healthy subjects.
INM-755 in Dermatology, page 4
8.We note your statement that findings from several toxicology studies support the safety of
CBN for continued clinical development. As safety is a determination that is solely within
the authority of the FDA and comparable foreign regulators and is assessed throughout all
phases of clinical trials, it is inappropriate to state or imply that your product candidates
will be determined to be safe. Please revise your disclosure to remove such implication
here and throughout your registration statement, e.g., on page 74 where you state CBN has
demonstrated several compelling pharmacological, toxicological and commercial features,
including unique safety properties.
Regulatory and Patent Strategy, page 5
9.Please expand this discussion to explain how this strategy differentiates you from
competitors.
Risks Related to our Business, page 8
10.Please expand the bullet point on the top of page 8 to highlight the risks related to the
current status of your patent portfolio.
Use of Proceeds, page 47
11.Please revise the discussion to identify the stage of development you expect to achieve
with the proceeds of the offering for INM-755 and INM-088. To the extent you expect to
begin a particular stage of development but do not expect to complete it, please indicate

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 May 11, 2020 Page 4
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InMed Pharmaceuticals Inc.
May 11, 2020
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that you will need to raise additional funding to complete that stage of development.
Business
Our Product Candidates and Technologies
Key Milestones, page 78
12.We note your disclosure on page 78 that you have entered into various agreements
with University of British Columbia.  In your Business section, please include a
description of the material terms of the agreements, including rights and
obligations, financial terms including amounts paid to date, aggregate milestone amounts
to be paid or received, the royalty range and term, as applicable, term and termination
provisions.  With regard to the royalty range, please disclose a royalty range of not more
than 10 percentage points.
Research and Development Pipeline of Therapeutic Drug Candidates
INM-755 for the Treatment of EB, page 80
13.We note your statements that "[i]t is well documented that phytocannabinoids, or plant-
derived cannabinoid compounds, have unique anti-inflammatory, analgesic and wound
healing promoting properties via several mechanisms" and that your "preclinical research
has identified a specific cannabinoid, CBN, that may prove beneficial to patients." These
statements imply efficacy and are presented as a conclusion. Please remove these and
similar statements throughout the registration statement.  Revise your disclosure to present
balanced data from your trials stating the actual results observed and quantifying the
results as necessary.
14.We note that CBN was studied in a panel of cannabinoids to determine its ability to
regulate keratin expression and that CBN induced a "statistically significant" upregulation
of K15 in 2 of the 3 experiments. Please indicate the p-value by which you measured
statistical significance and explain how p-value is used to measure statistical significance.
Please also revise to state whether the results observed in the other preclinical studies
presented in the section were statistically significant.
Summary of Contemplated Clinical Development Plans, page 94
15.We note that all subjects in this first clinical trial completed treatment and evaluations by
March 27, 2020.  For each your completed and contemplated clinical trials, please
disclose the scope and size; dosage and duration; and if applicable, the actual results
observed.
INM-088 for the Treatment of Glaucoma, page 98
16.We note that the preclinical trials discussed in this section provide results without
providing proper context for such results. For each of the preclinical trials discussed in
this section, please disclose the scope and size; dosage and duration; and actual results
observed.

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 May 11, 2020 Page 5
 FirstName LastName
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InMed Pharmaceuticals Inc.
May 11, 2020
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Intellectual Property, page 107
17.As to your material patents, clarify whether you directly own or license the patents and
patent applications. If licensed from a third party, please identify the third party.
Additionally, for each material patent, please identify all applicable jurisdictions where
patents are granted or patent applications are pending, disclose the scope of patent of
protection (e.g., composition of matter, use, or process) and patent expiry.
Material United States Federal Income Tax Considerations, page 138
18.Please revise to clearly state that the disclosure in this section is the opinion of the
respective counsels, and revise to remove language stating that "generally" certain tax
consequences will apply and express a firm opinion for each material tax consequence or
explain why such an opinion cannot be given.
General
19.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on our behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            You may contact Ibolya Ignat at 202-551-3636 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jeffrey Gabor at 202-551-2544 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Daniel M. Miller, Esq.