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                               April 18, 2024

       David P. Hochman
       Chief Executive Officer
       Orchestra BioMed Holdings, Inc.
       150 Union Square Drive
       New Hope, PA 18938

                                                        Re: Orchestra BioMed
Holdings, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1 on Form S-3
                                                            Filed March 27,
2024
                                                            File No. 333-274924

       Dear David P. Hochman:

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

              Please respond to this letter by amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our October 24, 2023
letter.

       Amendment No. 1 to Registration Statement on Form S-1 on Form S-3

       Cover Page

   1.                                                   We note your response
to prior comment 1 and re-issue in part. Where you disclose the
                                                        "weighted average per
share" price of common stock, please further revise to disclose the
                                                        price that the selling
securityholders paid for each of the securities being registered for
                                                        resale.
   2.                                                   We note your response
to prior comment number 4 that "the weighted average price of the
                                                        shares of common stock
being registered . . . was $6.65" and, therefore, the Company has
                                                        elected not to include
this information. While the average initial sale price of your
                                                        common stock is more
than the current market value, there remain selling shareholders
                                                        that will profit on
sales as a result of the lower initial price for which they purchased their
                                                        shares. Therefore,
these selling shareholders will have an incentive to sell their shares and
                                                        that public
securityholders may not experience a similar rate of return on the securities
 David P. Hochman
Orchestra BioMed Holdings, Inc.
April 18, 2024
Page 2
      they purchased. Please revise your cover page and risk factors to include
disclosure
      relating to certain selling shareholders' incentive to sell.
Risk Factors, page 8

3.    We note your response to prior comment 6 and re-issue in part. We note
the significant
      number of redemptions of your common stock in connection with your
business
      combination and that the shares being registered for resale will
constitute a considerable
      percentage of your public float. Please highlight in a risk factor here
the amount of shares
      being registered for resale could have a significant negative impact on
the public trading
      price of the common stock and the attendant risks.
       Please contact Benjamin Richie at 202-551-7857 or Lauren Nguyen at
202-551-3642
with any other questions.



                                                            Sincerely,

FirstName LastNameDavid P. Hochman                          Division of
Corporation Finance
                                                            Office of
Industrial Applications and
Comapany NameOrchestra BioMed Holdings, Inc.
                                                            Services
April 18, 2024 Page 2
cc:       Yariv Katz
FirstName LastName