September 24, 2025

James Martin
Co-Chief Executive Officer
Cocrystal Pharma, Inc.
4400 Biscayne Boulevard
Miami, FL 33137

       Re: Cocrystal Pharma, Inc.
           Registration Statement on Form S-1
           Filed September 19, 2025
           File No. 333-290407
Dear James 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 Tim Buchmiller at 202-551-3635 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Michael D. Harris, Esq.