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                              July 16, 2020

       Howard J. Weisman
       Chief Executive Officer
       PaxMedica, Inc.
       50 Tice Boulevard, Suite A26
       Woodcliff Lake, NJ 07677

                                                        Re: PaxMedica, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed July 2, 2020
                                                            File No. 333-239676

       Dear Mr. Weisman:

              We have reviewed your 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.

       Registration Statement on Form S-1

       Prospectus Summary
       Our Development Strategy, page 1

   1.                                                   We note your revised
disclosure in response to comment 1 that you believe there is a
                                                        reasonable likelihood
that you will receive approval of PAX-101 for the treatment of
                                                        HAT. This statement
conveys an expectation of regulatory approval which is
                                                        speculative and
inappropriate given the uncertainty with respect to securing marketing
                                                        approval. Please revise
your disclosure accordingly.
       PAX-102, page 3

   2.                                                   We note your response
to comment 5; however, you continue to state conclusions
                                                        regarding safety or
efficacy. Please revise your statement here that your proprietary
 Howard J. Weisman
FirstName
PaxMedica,LastNameHoward  J. Weisman
            Inc.
Comapany
July       NamePaxMedica, Inc.
     16, 2020
July 16,
Page  2 2020 Page 2
FirstName LastName
         intranasal formulations and methods of delivering suramin to mammals
have been shown
         to dramatically reduce systemic exposure to remove your conclusion
that data
         demonstrated safety or efficacy. You may present objective data
resulting from your trials
         without including conclusions related to safety or efficacy in the
Business section.
Risk Factors
Risks Related to Product Development, Regulatory Approval, Manufacturing and
Commercialization, page 12

3.       We note your response to comment 3, which we reissue in part. Please
revise your
         disclosure to highlight the risks associated with UCSD's conduct of
clinical trials
         of suramin and the impact UCSD's patent application discussed on page
28, if approved,
         may have on your development plans, your patent portfolio and your
business or tell us
         why you believe such disclosure is not required.
Use of Proceeds, page 42

4.       We note your revised disclosure in response to comment 7. Please
revise your disclosure
         to remove the implication that you will be successful in securing
marketing approval
         of PAX-101 for the treatment of HAT. Additionally, please revise to
provide more
         meaningful and specific disclosure of the intended use of proceeds, as
well as the
         approximate amounts intended to be used for each such purpose. This is
required even if
         management will have broad discretion in allocating the proceeds. This
section does not
         require disclosure of definitive plans and it is acceptable to provide
a quantitative
         discussion of preliminary plans. You may also reserve the right to
change the use of
         proceeds as indicated in Instruction 7 to Regulation S-K Item 504.
Dilution, page 45

5.       The historical net tangible book value of $32,000 and historical net
tangible book value
         per share of $0.00 as of March 31, 2020 appears to include the
preferred units in the
         mezzanine section of the balance sheet. Please revise the calculations
to exclude the
         mezzanine preferred units or advise as to the appropriateness of the
Company's
         calculation.
Business
Current Clinical Development Plan, page 56

6.       We note your response to comment 10, which we reissue in part. We note
your disclosure
         that you intend to conduct preclinical and clinical safety studies of
PAX-101 for the
         treatment of HAT yet you present PAX-101 for the treatment of this
indication as
         completing Phase 3 clinical trials in your pipeline table on page 56.
Please revise your
         pipeline table so that it accurately reflects the necessity to conduct
preclinical studies. We
         will not object to explanatory disclosure indicating, if true, that
you intend to rely on data
         exclusively licensed by you to support your application for marketing
approval.
 Howard J. Weisman
PaxMedica, Inc.
July 16, 2020
Page 3
7.    We note your response to comment 11, which we reissue in part. We note
that you have
      not provided any additional disclosure regarding preclinical studies
conducted for PAX-
      101 for the treatment of FXTAS or for PAX-102. Please provide us with
your analysis as
      to why these programs are material to your business and appropriate for
inclusion in the
      pipeline table. Please also remove your selective anti-purinergic therapy
program from
      your pipeline table. We will not object to a discussion of the program
below the table, but
      research and discovery activities that precede the identification of a
product candidate are
      too remote to be highlighted in the pipeline table.
Mitochondrial Dysfunction and Implications for the Use of Suramin for
Management of ASD
and FXTAS, page 58

8.    We note your revised disclosure in response to comment 13 that a single
dose of suramin
      exhibited "promising results" on the core symptoms of ASD. Because a
determination of
      efficacy is solely within the FDA's authority, please remove this
reference. You may
      present objective data resulting from clinical trials without including
conclusions related
      to efficacy. Please revise this statement as well as similar statements
throughout the
      prospectus that present conclusions regarding efficacy such as your
disclosure stating
      compounds demonstrated "strong early preclinical data."
        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.

       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 Ameen Hamady at 202-551-3891 or Sasha Parikh at
202-551-3627 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ada D. Sarmento at 202-551-3798 or Christine Westbrook at 202-551-5019
with any
other questions.



                                                            Sincerely,
FirstName LastNameHoward J. Weisman
                                                            Division of
Corporation Finance
Comapany NamePaxMedica, Inc.
                                                            Office of Life
Sciences
July 16, 2020 Page 3
cc:       Steven M. Skolnick, Esq.
FirstName LastName