United States securities and exchange commission logo





                              June 11, 2020

       John Temperato
       Chief Executive Officer
       9 METERS BIOPHARMA, INC.
       8480 Honeycutt Road, Suite 120
       Raleigh, NC 27615

                                                        Re: 9 METERS BIOPHARMA,
INC.
                                                            Registration
Statement on Form S-3
                                                            Filed June 1, 2020
                                                            File No. 333-238850

       Dear Mr. Temperato:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-3 filed June 1, 2020

       General

   1.                                                   We note you have not
provided financial statements in connection with your acquisition of
                                                        Naia Rare Diseases,
Inc. in this registration statement. Provide us with your analysis as to
                                                        why these financial
statements are not required, including the tests of significance for the
                                                        acquisition. Please see
Item 11(b)(i) of Form S-3 and Rule 8-04 of Regulation S-X.
   2.                                                   Please file the
financial statements referenced in your Form 8-K filed on May 4, 2020.
               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.
 John Temperato
9 METERS BIOPHARMA, INC.
June 11, 2020
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jeffrey Gabor at 202-551-2544 or Celeste Murphy at
202-551-3257
with any questions.



                                                           Sincerely,
FirstName LastNameJohn Temperato
                                                           Division of
Corporation Finance
Comapany Name9 METERS BIOPHARMA, INC.
                                                           Office of Life
Sciences
June 11, 2020 Page 2
cc:       Alexander M. Donaldson, Esq.
FirstName LastName