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                                October 2, 2020

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

                                                        Re: PaxMedica, Inc.
                                                            Amendment No. 6 to
Registration Statement on Form S-1
                                                            Filed September 29,
2020
                                                            File No. 333-239676

       Dear Mr. Weisman:

             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. 6 to Registration Statement on Form S-1

       Cover Page

   1.                                                   Please revise the first
paragraph to state the separate offering price for each of the
                                                        common stock and the
warrants even though they will be sold together for one combined
                                                        offering price. In the
alternative, please revise the registration statement to register units.
                                                        Please also revise the
cover page to clarify, if true, that fractional warrants will not be
                                                        issued and to disclose
the minimum number of shares that must be purchased in order to
                                                        receive one whole
warrant. We also note your disclosure on page 93 that the warrants will
                                                        include an exercise
limitation. Please expand your disclosure on page 7 under the heading
                                                        "Warrants we are
offering" to include the exercise limitation.
 Howard J. Weisman
PaxMedica, Inc.
October 2, 2020
Page 2
Capitalization, page 46

2.     Please update your pro forma as adjusted amounts in your capitalization
table to reflect
       the sale of the 2,625,000 shares and warrants rather than the previously
anticipated
       2,500,000 shares.
       You may contact Ameen Hamady at 202-551-5019 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
October 2, 2020 Page 2
cc:       Steven M. Skolnick, Esq.
FirstName LastName