May 2, 2019 James Martin Chief Financial Officer Cocrystal Pharma, Inc. 19805 N. Creek Parkway Bothell, WA 98011 Re: Cocrystal Pharma, Inc. Registration Statement on Form S-3 Filed April 25, 2019 File No. 333-231022 Dear Mr. Martin: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Christine Westbrook at 202-551-5019 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance cc: Brian Bernstein, Esq.