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                             January 26, 2022

       Joshua Disbrow
       Chief Executive Officer
       Aytu Biopharma, Inc.
       373 Inverness Parkway, Suite 206
       Englewood, Colorado 80112

                                                        Re: Aytu Biopharma,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended June 30, 2021
                                                            Filed September 28,
2021
                                                            File No. 001-38247

       Dear Mr. Disbrow:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended June 30, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, Comparison of the years ended June 30, 2021 and
2020, page 98

   1.                                                   We reference your
disclosures attributing material fluctuations in your revenues, costs and
                                                        expenses to multiple
factors. In future filings, please quantify each factor cited so that
                                                        investors may
understand the magnitude and relative impact of each factor. For example,
                                                        you should quantify the
impact of material acquisitions on revenue and costs of
                                                        revenues as well as the
amount of revenue loss attributed to terminated contracts.
                                                        Also consider providing
revenue fluctuations by product or product grouping. In
                                                        addition, future
filings should separately quantify research and development expenses by
                                                        each product candidate
for which significant investments were made during the periods,
                                                        e.g., for AR101 and
Healight. Refer to Item 303(b) of Regulation S-K.
 Joshua Disbrow
Aytu Biopharma, Inc.
January 26, 2022
Page 2
Critical Accounting Estimates, Impairment of Long-lived Assets, page 105

2.       We note your disclosure related to possible future Goodwill impairment
on page F-23. In
         regards to your goodwill and the related impairment evaluation, please
revise your future
         filings to identify the at-risk reporting units (i.e., fair value is
not substantially in excess of
         the carrying value) and disclose the percentage by which fair value
exceeded carrying
         value as of the date of the most recent test and the amount of
goodwill allocated to the
         reporting unit.
Item 9A. Controls and Procedures, page 106

3.       We note your discussion in the first paragraph under Evaluation of
Disclosure Controls
         and Procedures that as of June 30, 2021 as a result of the material
weakness in internal
         control over financial reporting your disclosure controls and
procedures were not
         effective. Please explain to us how you concluded that your internal
control over financial
         reporting is effective at June 30, 2021.
       In closing, 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.

      You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio,
Accounting
Branch Chief, at (202) 551-3676 with any questions.



FirstName LastNameJoshua Disbrow                                   Sincerely,
Comapany NameAytu Biopharma, Inc.
                                                                   Division of
Corporation Finance
January 26, 2022 Page 2                                            Office of
Life Sciences
FirstName LastName