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                              November 5, 2020

       David Baker
       Chief Executive Officer
       Vallon Pharmaceuticals, Inc.
       Two Logan Square
       100 N. 18th Street, Suite 300
       Philadelphia, PA 19103

                                                        Re: Vallon
Pharmaceuticals, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 23,
2020
                                                            File No. 333-249636

       Dear Mr. Baker:

              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

       Company Overview, page 1

   1.                                                   We note your response
to prior comment number 1. Please identify and describe the
                                                        studies and results you
intend to rely on for approval using the Section 505(b)(2) pathway,
                                                        including the
identification of the parties that performed the studies. Please also disclose
                                                        whether the FDA
approved the use of the Section 505(b)(2) pathway for ADAIR.
       Clinical Development, page 87

   2.                                                   We note your disclosure
on page 88 that one patient experienced a serious adverse event
                                                        in the food effect
study. Please describe the serious adverse event and whether it was
                                                        assessed as
drug-related.
 David Baker
Vallon Pharmaceuticals, Inc.
November 5, 2020
Page 2

        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 Gary Newberry at 202-551-3761 or Jeanne Baker at
202-551-3691 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Chris Edwards at 202-551-6761 or Mary Beth Breslin at 202-551-3625 with
any other
questions.



                                                           Sincerely,
FirstName LastNameDavid Baker
                                                           Division of
Corporation Finance
Comapany NameVallon Pharmaceuticals, Inc.
                                                           Office of Life
Sciences
November 5, 2020 Page 2
cc:       Kaoru C. Suzuki, Esq.
FirstName LastName