Cocrystal Pharma, Inc.

9805 North Creek Parkway

Bothell, Washington


May 12, 2020



Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D. C. 20549

Attention: Mr. Tim Buchmiller


  Re: Cocrystal Pharma, Inc.
    Registration Statement on Form S-3
    File No. 333-237738


Dear Mr. Buchmiller:


In accordance with Rule 461 promulgated pursuant to the Securities Act of 1933, Cocrystal Pharma, Inc. (the “Company”) is hereby requesting that the effective date of the above-referenced Registration Statement be accelerated so that the same will become effective at 4:00 p.m. on May 13, 2020, or as soon thereafter as may be practicable.


If you have any questions regarding this request, please contact Michael Harris, our legal counsel at (561) 644-2222.


  Very truly yours,
  /s/ James Martin
  James Martin
  Chief Financial Officer




Michael D. Harris, Esq.

Constantine Christakis, Esq.