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 FIRST TRACKS BIOTHERAPEUTICS, INC.

 10770 Wateridge Circle, Suite 210

 San Diego, CA 92121

 May 8, 2026

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Alan Campbell

 Division of Corporation Finance

 Office of Life Sciences

 First Tracks Biotherapeutics, Inc.
Registration Statement on
 Form S-1 (File No. 333-295719)

 Dear Mr. Campbell:

 Pursuant to Rule 461 of the Securities Act of
1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-1 (the "S-1")
relating to the registration of 10,497,054 shares of the common stock, par value $0.001 per share, of First Tracks Biotherapeutics, Inc.
(the "Company"), be accelerated to May 12, 2026 at 4:00 p.m. E.D.T. or as soon thereafter as may be practicable, or at such
other time as the Company or its outside counsel, Paul, Weiss, Rifkind, Wharton & Garrison LLP, may orally request via telephone call
that the S-1 be declared effective.

 We understand that the Staff will consider this
request as confirmation by the Company of its awareness of its responsibilities under the federal securities laws as they relate to the
issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Christodoulos
Kaoutzanis of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3445.

 *****

 Very truly yours,

 By:
 /s/ Daniel Faga

 Name:
 Daniel Faga

 Title:
 President and Chief Executive Officer

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<TEXT>
 May 6, 2026

Daniel Faga
President and Chief Executive Officer
First Tracks Biotherapeutics, Inc.
10770 Wateridge Circle, Suite 210
San Diego, CA 92121

 Re: First Tracks Biotherapeutics, Inc.
 Draft Registration Statement on Form S-1
 Submitted May 1, 2026
 CIK No. 0002091349
Dear Daniel Faga:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
Please refer to Rules 460 and 461 regarding requests for acceleration. We
remind you that the
company and its management are responsible for the accuracy and adequacy of
their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

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

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Christodoulos Kaoutzanis, Esq.
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