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                            November 3, 2022

       Vininder Singh
       Chief Executive Officer
       BullFrog AI Holdings, Inc.
       325 Ellington Blvd., Unit 317
       Gaithersburg, MD 20878

                                                        Re: BullFrog AI
Holdings, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 19,
2022
                                                            File No. 333-267951

       Dear Vininder Singh:

              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.

       Form S-1 filed October 19, 2022

       Our bfLEAP Analytics Platform, page 3

   1.                                                   We refer to the updated
disclosure you provide concerning a new JHU-APL license which
                                                        you executed on July 8,
2022. Please revise to describe the additional technology that you
                                                        licensed so that it is
clear whether the technology relates solely to development of your
                                                        AI/ML platform and/or
whether it includes intellectual property covering new drug
                                                        programs. In this
regard, we note that your revised Use of Proceeds disclosure on page 23
                                                        references planned
allocations to "newly licensed drug programs" and that you also
                                                        removed disclosure
indicating that you planned to use offering proceeds to fund the
                                                        Mebendazole and siRNA
programs, which are the only two drug programs highlighted in
                                                        the Summary and
explained in the Business section.
 Vininder Singh
FirstName
BullFrog AILastNameVininder  Singh
            Holdings, Inc.
Comapany 3,
November   NameBullFrog
             2022         AI Holdings, Inc.
November
Page 2    3, 2022 Page 2
FirstName LastName
John Hopkins University - Mebendazole License, page 5

2.       We note your revised disclosure in response to prior comment 2 and
reissue. It
         remains unclear what basis you have to state that your Phase 1 trial
assessed efficacy.
         Please remove the statement or revise to explain whether the Phase 1
trial was powered to
         assess efficacy and whether the results were statistically
significant.
Planned Reverse Stock Split, page 6

3.       We note that you intend to affect a 1-for-7 reverse stock split of
your common stock prior
         to the effectiveness of the offering. We remind you that in accordance
with SAB Topic
         4:C, you will need to revise your financial statements and your
disclosures throughout the
         filing to give effect to the expected stock split. Your auditor's
report must also be updated
         to reflect the reverse stock split in accordance with Auditing
Standard (AS) 3110.05.
Capitalization, page 23

4.       Your introduction to your capitalization table indicates that the
table sets forth your cash
         and cash equivalents as of June 30, 2022. Please revise to indicate
that it also presents
         your capitalization and indebtedness as of this date.
Use of Proceeds, page 23

5.       We note your revised disclosure in response to prior comment 4. Please
further revise
         your Use of Proceeds section to identify each newly licensed drug
program that you plan
         to fund and the attendant dollar amount attributable to each program.
Also, state how far
         in the development process you estimate the allocated proceeds from
this offering will
         enable you to reach for each newly licensed drugs. Please also revise
to set forth the
         interest rate and maturity of any indebtedness to be discharged with
the proceeds from this
         offering. If any of the indebtedness to be discharged was incurred
within one year,
         describe the use of the proceeds of such indebtedness other than
short-term borrowings
         used for working capital. Refer to Item 504 of Regulation S-K for
guidance.
Business
Our Products, page 33

6.       We note your revised disclosure in response to prior comment 6 and
reissue in part.
         Please replace the "Current Market" header on this chart with a more
appropriate
         description, as disclosure elsewhere indicates that neither of your
clinical candidates are
         currently approved for commercial sale. Please also revise this
section to describe any
         development activities you have conducted for the siRNA program. In
this regard, you
         indicate that the program is currently in the preclinical stage of
development but there is
         no discussion of what work has been conducted, is currently being
conducted or is
         planned for the future. To the extent you have not yet conducted any
development
         activities on this program, please revise to make this point clear
throughout the
 Vininder Singh
BullFrog AI Holdings, Inc.
November 3, 2022
Page 3
       prospectus.
Our Market Opportunity, page 36

7.     We note your revised disclosure in response to prior comment 7 and
reissue in part.
       Please further revise this section to explain what steps you will need
to take before you are
       able to commercialize the product candidates discussed in this section.
For instance,
       please explain that it may be costly or difficult to acquire
intellectual property rights to the
       failed drugs and that you may need to conduct significant preclinical
work and clinical
       trial work and obtain FDA approval prior to any commercialization
efforts.
Intellectual Property, page 37

8.     We note your revised disclosure in response to prior comment 8 and
reissue in part.
       Please revise to include the expiration dates or potential expiration
dates, if granted, for
       each patent or patent application licensed from George Washington
University that is
       disclosed in this section.
        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 Ibolya Ignat at 202-551-3636 or Angela Connell at
202-551-3426 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tyler Howes at 202-551-3370 or Joe McCann at 202-551-6262 with any
other questions.



                                                               Sincerely,
FirstName LastNameVininder Singh
                                                               Division of
Corporation Finance
Comapany NameBullFrog AI Holdings, Inc.
                                                               Office of Life
Sciences
November 3, 2022 Page 3
cc:       Arthur Marcus, Esq.
FirstName LastName