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                             September 29, 2022

       Lewis Bender
       Chief Executive Officer
       Intensity Therapeutics, Inc.
       61 Wilton Road, 3rd Floor
       Westport, CT 06880

                                                        Re: Intensity
Therapeutics, Inc.
                                                            Amendment No. 8 to
Registration Statement on Form S-1
                                                            Filed September 20,
2022
                                                            File No. 333-260565

       Dear Mr. Bender:

             We have reviewed your amended registration statement 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 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.

       Amendment No. 8 to Form S-1 filed September 20, 2022

       Use of Proceeds, page 37

   1.                                                   We note your revised
disclosure on page 37 that approximately 25% of the net proceeds
                                                        from the offering will
be allocated toward "initiating/conducting a Phase 3 sarcoma and/or
                                                        Phase 2/3 early-stage
breast cancer studies (IT-03 and IT-04)," your two most advanced
                                                        programs. Please
clarify the approximate amount of proceeds you intend to allocate
                                                        towards each of the
IT-03 and IT-04 programs identified and how far the proceeds from
                                                        the offering will allow
you to proceed with the continued development of each of these
                                                        programs.
 Lewis Bender
FirstName  LastNameLewis
Intensity Therapeutics, Inc. Bender
Comapany 29,
September  NameIntensity
               2022        Therapeutics, Inc.
September
Page 2     29, 2022 Page 2
FirstName LastName
Our Pipeline, page 52

2.       We note your references to the IT-01, IT-02, IT-03 and IT-04 studies
throughout the
         prospectus, including in the Use of Proceeds and Business sections.
Please update your
         pipeline table to identify the relevant IT-01, IT-02, IT-03 and IT-04
studies accordingly.
INT230-6 Efficacy in Soft Tissue Sarcoma, page 75

3.       We refer to your disclosure on page 76 that the escalation in dosage
of up to 175 mL of
         INT230-6 per session had "favorable safety." Please expand your
disclosure to discuss
         whether any adverse events were observed in this trial.
Employment Agreements, page 106

4.       We note your disclosure on page 107 that you are currently negotiating
an agreement with
         Portage Development Services, Inc. for "use of staff time," which
includes time for Dr.
         Walters. Please expand your disclosure to discuss your relationship
with Portage
         Development Services, whether the working time of additional employees
of the
         company, and the percentage of working time Dr. Walters and other
employees will
         continue to devote to the company, as applicable.
       You may contact Sasha Parikh at 202-551-3627 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jane Park at 202-551-7439 or Christopher Edwards at 202-551-6761 with any other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences
cc:      Daniel Woodard, Esq.