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                               May 20, 2021

       Richard Ackerman
       Chief Executive Officer
       Big Rock Partners Acquisition Corp.
       2645 N. Federal Highway, Suite 230
       Delray Beach, FL 33483

                                                        Re: Big Rock Partners
Acquisition Corp.
                                                            Amendment No. 4 to
Registration Statement on Form S-4
                                                            Filed May 20, 2021
                                                            File No. 333-252479

       Dear Mr. Ackerman:

             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.
Unless we note
       otherwise, our references to prior comments are to comments in our May
19, 2021 letter.

       Amendment No. 4 to Registration Statement on Form S-4

       Cover page

   1.                                                   We refer to prior
comment 1. Please revise the cover page to explain what steps you and
                                                        the parties would take
in the event of a delisting prior to the meeting and/or closing of the
                                                        merger. Explain how
investors would be informed.
       Proposal No. 7 - The Adjournment Proposal, page 170

   2.                                                   With reference to your
disclosure on page F-36, we note that your amended charter
                                                        requires that you
consummate a Business Combination by May 24, 2021. Accordingly,
                                                        please revise Proposal
No. 7 to limit the duration of the adjournment so that it does not
                                                        extend beyond May 24,
2021 or advise.
 Richard Ackerman
Big Rock Partners Acquisition Corp.
May 20, 2021
Page 2
General

3.    We refer to prior comment 12. As stated during our telephone conversation
with your
      counsel earlier today, we have concerns with respect to the manner and
timing by which
      you plan to disseminate the joint proxy/prospectus in relation to the
BRPA shareholder
      meeting and closing of the merger, which are both scheduled for Monday,
May 24, 2021.
      Accordingly, we make no representation as to the sufficiency of the time
that you plan to
      provide the BRPA shareholders: (i) to make an informed voting decision on
the proposals;
      and (ii) to make an informed investment decision with respect to
conversion of their
      shares. In addition, we make no representation as to whether the manner
or timing of the
      delivery to the NeuroRx holders satisfies the delivery requirements under
the Securities
      Act.
       You may contact Tracie Mariner at (202) 551-3744 or Al Pavot at (202)
551-3738 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alan Campbell at (202) 551-4224 or Joe McCann at (202) 551-6262 with
any other
questions.



                                                          Sincerely,
FirstName LastNameRichard Ackerman
                                                          Division of
Corporation Finance
Comapany NameBig Rock Partners Acquisition Corp.
                                                          Office of Life
Sciences
May 20, 2021 Page 2
cc:       Jeffrey M. Gallant, Esq.
FirstName LastName