August 28, 2025 James Martin Co-Chief Executive Officer and CFO Cocrystal Pharma, Inc. 19805 North Creek Parkway Bothell, WA 98011 Re: Cocrystal Pharma, Inc. Form 10-K for the fiscal year ended December 31, 2024 Filed March 31, 2025 File No. 001-38418 Dear James Martin: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Life Sciences