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                             April 27, 2022

       Jennifer Simpson, Ph.D.
       Chief Executive Officer
       Panbela Therapeutics, Inc.
       712 Vista Boulevard #305
       Waconia, Minnesota 55387

                                                        Re: Panbela
Therapeutics, Inc.
                                                            Preliminary Revised
Proxy Statement on Schedule 14A
                                                            Filed April 26,
2022
                                                            File No. 001-39468

       Dear Dr. Simpson:

               We have reviewed your April 26, 2022 response to our comment
letter and have the
       following comment. In our comment, we may ask you to provide us with
information so we may
       better understand your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this comment, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       April 21, 2022 letter.

       Preliminary Proxy Statement on Schedule 14A filed April 26, 2022

       Proposal 3: Approval of the Issuance of Common Stock in Connection with
Acquisition, page 20

   1.                                                   We note your response
to prior comment 1 and reissue it in part. If accurate, please revise
                                                        your description of
proposal 3 to clarify that you are seeking authorization to issue up to
                                                        11,003,823 shares of
common stock as partial consideration for your acquisition of Cancer
                                                        Prevention
Pharmaceuticals. Additionally, clarify your statement on page 21 that if
                                                        Proposal No. 3 is
approved, you would issue shares of common stock up to an amount
                                                        representing 69.5% of
your issued and outstanding securities as of the record date.
              Please contact Tyler Howes at 202-551-3370 or Suzanne Hayes at
202-551-3675 with
       any questions.
 Jennifer Simpson, Ph.D.
Panbela Therapeutics, Inc.
April 27, 2022
Page 2

                                            Sincerely,
FirstName LastNameJennifer Simpson, Ph.D.
                                            Division of Corporation Finance
Comapany NamePanbela Therapeutics, Inc.
                                            Office of Life Sciences
April 27, 2022 Page 2
cc:       W. Morgan Burns, Esq.
FirstName LastName