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CORRESP
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 CORRESP

 Atrium Therapeutics, Inc.
 10578 Science Center Drive, Suite 125
 San Diego, California 92121
 February 24, 2026 VIA EDGAR
 Securities and Exchange Commission Division of Corporation
Finance Office of Life Sciences 100 F Street, N.E.,
 Washington, D.C. 20549

 Re:
 Atrium Therapeutics, Inc.
 Registration Statement on Form 10 (File No. 001-43008)
 Ladies and Gentlemen: Pursuant to Section 12(d) of the
Securities Exchange Act of 1934, as amended, and Rule 12d1-2 promulgated thereunder, Atrium Therapeutics, Inc. (the “Company”) hereby requests that the effective date of the Company’s
Registration Statement on Form 10, Registration Number 001-43008 (the “Registration Statement”), filed with the Securities and Exchange Commission (the “Commission”) be accelerated to
12:00 p.m., Eastern Time, on February 26, 2026, or as soon as practicable thereafter. In connection with this request, the Company hereby
acknowledges that:

 •

 should the Commission or the staff of the Division of Corporation Finance (the “Staff”), acting
pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to such Registration Statement;

 •

 the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration
Statement effective, does not relieve the Company from its full responsibility for the adequacy of the disclosure in the Registration Statement; and

 •

 the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States. Please contact Tamar Donikyan of
Kirkland & Ellis LLP via telephone at (212) 909-3421, or via e-mail at (tamar.donikyan@kirkland.com) with any questions and please notify her when this request
for acceleration has been granted.

 Sincerely,

 /s/ Kathleen Gallagher

 Name: Kathleen Gallagher

 Title: Chief Executive Officer

 cc:
 Daniel Crawford, Securities and Exchange Commission

  
 Jason Drory, Securities and Exchange Commission

  
 Eric Atallah, Securities and Exchange Commission

  
 Daniel Gordon, Securities and Exchange Commission

  
 Jennifer Lee, Esq., Kirkland & Ellis LLP

  
 Tamar Donikyan, Esq., Kirkland & Ellis LLP

CORRESP
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 January 29, 2026
 VIA EDGAR Division of Corporation Finance
 Office of Life Sciences Securities and Exchange Commission
 100 F Street, N.E. Washington, D.C. 20549-9303

 Attention:

 Eric Atallah Daniel Gordon
 Daniel Crawford Jason Drory

 Re:

 Atrium Therapeutics, Inc.
 Registration Statement on Form 10-12B
 Filed December 10, 2025 File No. 001-43008
 Ladies and Gentlemen:
 On behalf of Atrium Therapeutics, Inc. (the “ Company ”), set forth below are the Company’s responses to the comments of
the staff of the Division of Corporation Finance (the “ Staff ”) of the Securities and Exchange Commission in their letter, dated January 26, 2026, relating to the Company’s Registration Statement on Form 10-12B filed on December 10, 2025 (the “ Registration Statement ”). Concurrently with the submission of this letter, the Company has publicly filed Amendment No. 1 to the Registration
Statement (“ Amendment No. 1 ”), which reflects the revisions described herein and certain other updated information.
 For ease of reference, the text of the comments in the Staff’s letter has been reproduced herein, with the Company’s response
immediately following each numbered comment. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in Amendment No. 1.
 Registration Statement on Form 10 Information
Statement Summary Company Overview, page 10

 1.
 Staff’s Comment : Please revise under this heading to disclose, as you do on page 14, that
prior to or following the Spin-Off, you may have diminished assets to the extent a ROFN Sale occurs. In addition, please revise your disclosure as follows:

 •

 Identify the material assets that are subject to the ROFN;

 •

 identify the third party;

 •

 clarify whether the ROFN period commenced; and

 •

 describe the material terms and conditions of the negotiation period, or otherwise advise.
 Response : We respectfully advise the Staff that the negotiation period of the ROFN expires by its terms on February 5, 2026.
The ROFN Holder recently communicated to Avidity that it does not plan to proceed with negotiation of a ROFN Sale. As a result, we anticipate that an amendment to the Registration Statement filed after February 5, 2026 and before the
effectiveness of the Registration Statement will disclose that the negotiation period of the ROFN has expired and that no ROFN Sale will occur.

 Our Strategy, page 10

 2.
 Staff’s Comment : Please revise to remove your statement on page 10 and elsewhere
that your RNA delivery platform is “clinically-validated” as it does not appear that the FDA has approved any therapeutics using this platform, or otherwise advise.
 Response : In response to the Staff’s comment, the Company has revised the disclosure on pages 9, 105 and 107 of Amendment
No. 1. Our Development Programs, page 11

 3.
 Staff’s Comment : Please revise page 11 and elsewhere to remove statements that you may “de-risk” your drug development programs as it implies that you can mitigate the risk associated with drug development. Also, revise to disclose how you believe prioritizing rare cardiomyopathies will
“accelerate” your drug development. Response : In response to the Staff’s comment, the
Company has revised the disclosure on pages 10, 109 and 148 of Amendment No. 1.

 4.
 Staff’s Comment: Please revise your pipeline table on page 12 and elsewhere to
disclose the indications and targets for the two “rare cardio indication” programs. To the extent these programs are immaterial, revise to remove these programs from your pipeline tables. Also, revise your pipeline tables to include 3
columns for each phase of clinical development (Phase 1, Phase 2 and Phase 3), or otherwise advise.
 Response : In response to the Staff’s comment, the Company has revised the pipeline table on pages 11, 109 and 147 of
Amendment No. 1. Summary of Risk Factors, page 12

 5.
 Staff’s Comment : Please revise your summary risk factor disclosure to identify the
risk starting on page 42 that Novartis, through its control of RemainCo, may compete directly with you in the cardiac space using your RNA delivery platform.
 Response : In response to the Staff’s comment, the Company has revised the disclosure on page 13 of Amendment No. 1.
 Business Our Cardiac Disease Pipeline, page 110

 6.
 Staff’s Comment : Please revise page 110 to provide the basis for your belief that
“PRKAG2 and PLN are cardiology targets with high probabilities of clinical success” and please balance this disclosure to state that even if you determine these targets have the highest probability of success as compared to other
indications, you may still fail to develop an approved therapeutic for all of these indications. Response :
In response to the Staff’s comment, the Company has revised the disclosure on page 109 of Amendment No. 1.

 Preclinical Data and Next Steps, page 111

 7.
 Staff’s Comment: Please revise page 112 to disclose all “higher species”
included in the preliminary tolerability data, provide the number of each species tested in the study and the number of mice subjects in your mouse model of PRKAG2 syndrome. Also, revise to provide the same disclosure as it relates to the
preclinical data for ATR 1086 starting on page 113. Response : In response to the Staff’s comment,
the Company has revised the disclosure on pages 106, 111, 112, 113 and 148 of Amendment No. 1. Research Collaboration and License Agreement with
Lilly, page 119

 8.
 Staff’s Comment: If material, please revise under this heading to disclose the “other
select indications” subject to the Research Collaboration and License Agreement with Lilly, or otherwise advise.
 Response : In response to the Staff’s comment, the Company has revised the disclosure on pages 37 and 120 of Amendment
No. 1. Research Collaboration and License Agreement and Securities Purchase Agreement with BMS, page 119

 9.
 Staff’s Comment : Please revise to disclose the royalty rates pursuant to your
agreements with BMS and Lilly to a range within 10 percentage points, or otherwise advise. Also, revise your disclosure here to disclose how the agreements may be terminated. To this point, we note your disclosure on page 37 that “Lilly or BMS
may each unilaterally terminate its respective agreement with [you] for convenience.” Response : In
response to the Staff’s comment, the Company has revised the disclosure on pages 119 and 120 of Amendment No. 1. Notes to the Unaudited Pro
Forma Condensed Combined Financial Information, page 144

 10.
 Staff’s Comment : We note that adjustments (c) and (d) relate to lab
equipment and leased assets that will be entered into as part of the separation with Avidity Biosciences Inc. Please tell us how the lab equipment and leased assets were accounted for in your pro forma balance sheet. Refer to Item 11-02(a)(6)(i)(A) of Regulation S-X.
 Response : In response to the Staff’s comment, the Company confirms that all of the laboratory equipment and leased assets
expected to be transferred as part of the separation from Avidity were included in the historical carve out balance sheet and were identified as Company-specific assets. The laboratory equipment was included within the line item “Property and
equipment, net”, and the leased assets and related obligations were included within the line items “Right of use assets”, “Lease liabilities, current portion”, and “Lease liabilities, net of current
portion”. Accordingly, no separate pro forma balance sheet adjustment was required for these assets under Regulation S-X Rule 11-02(a)(6)(i)(A). Additionally, as
the laboratory equipment and leased assets were shared with Avidity and not exclusively used by the Company, the related depreciation and lease expense in the historical carve out statements of operations reflects the net expense after allocation
using the corporate allocation methodology applied in the preparation of the carve out financial statements. Pro forma adjustments (c) and (d) therefore reflect the incremental depreciation and lease expense attributable to the laboratory
equipment and leased assets that will be utilized exclusively by the Company on a go forward basis, in order to present the pro forma effects of the separation in accordance with Regulation S-X Rule 11-02(a)(6)(i)(A). * * * * * *

 Should any member of the Staff have any questions or require any additional information with
respect to the enclosed materials, please do not hesitate to contact Jennifer L. Lee at (212) 909-3021 or jennifer.lee@kirkland.com, or Tamar Donikyan at (212) 909-3421
or tamar.donikyan@kirkland.com.

 Sincerely,

 /s/ Kathleen Gallagher

 Kathleen Gallagher

 Chief Executive Officer and Director

 cc:
 Jennifer L. Lee, P.C., Kirkland & Ellis LLP
 Tamar Donikyan, Kirkland & Ellis LLP

<DOCUMENT>
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<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 January 26, 2026

Kathleen Gallagher
Chief Executive Officer and Director
Atrium Therapeutics, Inc.
10578 Science Center Drive, Suite 125
San Diego, CA 92121

 Re: Atrium Therapeutics, Inc.
 Registration Statement on Form 10
 Filed December 10, 2025
 File No. 001-43008
Dear Kathleen Gallagher:

 We have reviewed your filing and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Registration Statement on Form 10
Information Statement Summary
Company Overview, page 10

1. Please revise under this heading to disclose, as you do on page 14, that
prior to or
 following the Spin-Off, you may have diminished assets to the extent a
ROFN Sale
 occurs. In addition, please revise your disclosure as follows:
 Identify the material assets that are subject to the ROFN;
 identify the third party;
 clarify whether the ROFN period commenced; and
 describe the material terms and conditions of the negotiation
period, or otherwise
 advise.
Our Strategy, page 10

2. Please revise to remove your statement on page 10 and elsewhere that
your RNA
 delivery platform is clinically-validated as it does not appear
that the FDA has
 January 26, 2026
Page 2

 approved any therapeutics using this platform, or otherwise advise.
Our Development Programs, page 11

3. Please revise page 11 and elsewhere to remove statements that you may
de-risk your
 drug development programs as it implies that you can mitigate the risk
associated with
 drug development. Also, revise to disclose how you believe prioritizing
rare
 cardiomyopathies will accelerate your drug development.
4. Please revise your pipeline table on page 12 and elsewhere to disclose
the indications and
 targets for the two rare cardio indication programs. To the extent
these programs are
 immaterial, revise to remove these programs from your pipeline tables.
Also, revise your
 pipeline tables to include 3 columns for each phase of clinical
development (Phase 1,
 Phase 2 and Phase 3), or otherwise advise.
Summary of Risk Factors, page 12

5. Please revise your summary risk factor disclosure to identify the risk
starting on page 42
 that Novartis, through its control of RemainCo, may compete directly
with you in the
 cardiac space using your RNA delivery platform.
Business
Our Cardiac Disease Pipeline, page 110

6. Please revise page 110 to provide the basis for your belief that
PRKAG2 and PLN are
 cardiology targets with high probabilities of clinical success and
please balance this
 disclosure to state that even if you determine these targets have the
highest probability of
 success as compared to other indications, you may still fail to develop
an approved
 therapeutic for all of these indications.
Preclinical Data and Next Steps, page 111

7. Please revise page 112 to disclose all higher species included in
the preliminary
 tolerability data, provide the number of each species tested in the
study and the number
 of mice subjects in your mouse model of PRKAG2 syndrome. Also, revise to
provide the
 same disclosure as it relates to the preclinical data for ATR 1086
starting on page 113.
Research Collaboration and License Agreement with Lilly, page 119

8. If material, please revise under this heading to disclose the other
select indications
 subject to the Research Collaboration and License Agreement with Lilly,
or otherwise
 advise.
Research Collaboration and License Agreement and Securities Purchase Agreement
with BMS,
page 119

9. Please revise to disclose the royalty rates pursuant to your agreements
with BMS and
 Lilly to a range within 10 percentage points, or otherwise advise. Also,
revise your
 disclosure here to disclose how the agreements may be terminated. To
this point, we note
 your disclosure on page 37 that Lilly or BMS may each unilaterally
terminate its
 respective agreement with [you] for convenience.
 January 26, 2026
Page 3

Notes to the Unaudited Pro Forma Condensed Combined Financial Information, page
144

10. We note that adjustments (c) and (d) relate to lab equipment and leased
assets that will be
 entered into as part of the separation with Avidity Biosciences Inc.
Please tell us how the
 lab equipment and leased assets were accounted for in your pro forma
balance
 sheet. Refer to Item 11-02(a)(6)(i)(A) of Regulation S-X.
 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 Eric Atallah at 202-551-3663 or Daniel Gordon at
202-551-3486 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Crawford at 202-551-7767 or Jason Drory at 202-551-8342 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Jennifer Lee, Esq.
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