November 21, 2024

Tien-Li Lee, M.D.
Chief Executive Officer
Aardvark Therapeutics, Inc.
4370 La Jolla Village Drive, Suite 1050
San Diego, CA 92122

       Re: Aardvark Therapeutics, Inc.
           Draft Registration Statement on Form S-1
           Submitted October 24, 2024
           CIK No. 0001774857
Dear Tien-Li Lee M.D.:

       We have reviewed your draft registration statement and have the
following comments.

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

      After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1 submitted October 24, 2024
Prospectus Summary, page 2

1.     Please provide balancing disclosure in the Prospectus Summary concerning
the
       following:
           your history of net losses and accumulated deficit, quantifying
each;
           your ability to continue as a going concern; and
           the current competitive landscape surrounding the treatment of
obesity and
           obesity-related conditions, relevant to your development of ARD-201.
2.     Please revise or remove statements both here and throughout the
prospectus implying
       that your product candidates are or may be determined to be safe and/or
effective.
       Examples of such statements include, but are not limited to, the
following:
 November 21, 2024
Page 2

              that you have "observed promising clinical benefit with an
encouraging
            tolerability profile";
           that you believe your product candidates can "offer enhanced
efficacy, tolerability
            and convenience over existing therapies to provide superior
benefits to patients";
           that you have "successfully" completed certain clinical trials; and
           your statement that "ARD-201   s full potential remains to be
discovered in future
            trials, with enhanced potency through combination with a DPP-4
inhibitor, and
            without the constraints in the Phase 2a clinical trial design".
       Note that conclusions of safety and efficacy are within the sole purview
of the FDA.
       Given the fact that your products candidates have not yet been approved
by the FDA,
       it is premature to state or imply that your product candidates are safe
and/or effective.
       Rather than including conclusory statements, you may include information
regarding
       data observed in trials to date. In addition, based on the uncertainty
surrounding the
       timing of clinical trials, please remove your statement that you plan to
pursue
       "accelerated development" of ARD-101.
3.     We note your statement that the administration of CCK may significantly
reduce food
       consumption in patients with hyperphagia associated with HO. Please cite
the specific
       literature mentioned as the source for this claim.
4.     We note your references both here and elsewhere to a "potentially
pivotal Phase 3
       clinical trial" for ARD-101. We also note your statements on page 25
that you have
       not previously conducted any later stage or pivotal clinical trials and
that in order to
       do so, you "will need to expand [y]our clinical management and
regulatory
       capabilities." Please provided more detail regarding the steps needed to
be taken prior
       to conducting this trial in each instance where the "potentially pivotal
Phase 3" is
       discussed.
We plan to conduct certain clinical trials for our product candidates outside
the . . ., page 26

5.     We note your statement that you plan to conduct certain clinical trials
of ARD-101
       and ARD-201 outside the U.S., including, but not limited to, in "the EU,
Australia and
       Asia". Please expand this disclosure to clarify the specific countries
in which the
       company has already conducted clinical trials, specifying the trial, and
where the
       company currently plans to conduct trials in the future.
An active and liquid trading market for our common stock may not develop...,
page 76

6.     We note your statement in the above entitled risk factor that there is
no assurance that
       your application to list your common stock on the Nasdaq Global Market
will be
       approved. We also note your statement on the cover page and pages 194
and 204 that
       the offering is contingent upon obtaining approval of such listing.
Please reconcile
       these statements.
 November 21, 2024
Page 3

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of the Six Months Ended June 30, 2023 and 2024
Research and Development Expenses, page 105

7.     You disclose on page 3 that you are pursuing two indications for ARD-101
and one
       indication for ARD-201. For each significant research and development
project,
       please disclose the costs incurred during each period. If the company
does not track
       research and development costs by individual project, please clarify in
the filing.
Critical Accounting Estimates
Stock-Based Compensation Expense, page 111

8.     Once you have an estimated offering price or range, please explain to us
how you
       determined the fair value of the common stock underlying your equity
issuances and
       the reasons for any differences between the recent valuations of your
common stock
       leading up to the initial public offering and the estimated offering
price. This
       information will help facilitate our review of your accounting for
equity issuances
       including stock compensation. Please discuss with the staff how to
submit your
       response.
Our Strategy, page 118

9.     We note your statements throughout the prospectus indicating you believe
that ARD-
       201 has "the potential to address the gaps associated with GLP-1
treatments", which
       include weight regain post-withdrawal and the loss of lean body mass.
Please revise
       your disclosure to explain why you do not believe these will be issues
with ARD-
       201 and provide data supporting your statements.
ARD-101 Preclinical Data Summary, page 123

10.    Please define "tachyphylaxis" where first used on page 123.
ARD-101, page 125

11.    Please revise Figure 3 and other figures, as appropriate, to provide a
clear key for the
       colors used in the bar graph representations.
Government Regulations, page 136

12.    Please update the disclosure in your Government Regulations section to
disclose how
       the regulatory framework for your fixed-dose combination of the ARD-201
product
       candidate may differ from your other product candidates in development
or otherwise
       advise. Also, revise your risk factor disclosure to include a discussion
of
       any material risks arising from your development of a fixed-dose
combination product
       candidate.
Intellectual Property, page 136

13.    Please revise your intellectual property disclosure to clearly describe
for each material
       individual or patent family the type of patent protection (e.g.,
composition of matter,
       use or process), the product candidate(s) dependent on each patent or
patent family,
 November 21, 2024
Page 4

       the expiration dates of each patent or patent family discussed, and the
jurisdiction of
       each. In this regard, it may be useful to provide this disclosure in
tabular form to
       support the narrative already included.
Statements of Cash Flows, page F-6

14.    Please explain to us why you have classified your payment made in
exchange for
       related party convertible promissory notes as a financing activity.
Refer to ASC 230-
       10-45-15.
General

15.    Please supplementally provide us with copies of all written
communications, as
       defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
       on your behalf, present to potential investors in reliance on Section
5(d) of the
       Securities Act, whether or not they retain copies of the communications.
       Please contact Eric Atallah at 202-551-3663 or Mary Mast at 202-551-3613
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tamika Sheppard at 202-551-8346 or Laura Crotty at 202-551-7614 with
any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Life
Sciences
cc:   Jeff Hartlin