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                             August 1, 2023

       Stephen LaMond, PharmD, MBA
       Interim Chief Executive Officer
       Peak Bio, Inc.
       4900 Hopyard Road, Suite 100
       Pleasanton, CA 94588

                                                        Re: Peak Bio, Inc.
                                                            Post-Effective
Amendment No. 1 to Form S-1
                                                            Filed July 24, 2023
                                                            File No. 333-268801

       Dear Stephen LaMond:

              We have reviewed your post-effective amendment 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.

       Post-Effective Amendment No. 1 to Form S-1

       General

   1.                                                   We note that the Form
S-1 declared effective on March 1, 2023 registered, among other
                                                        things, the resale of
up to 4 million shares of common stock following issuance to White
                                                        Lion Capital, LLC
("White Lion") pursuant to a Common Stock Purchase Agreement
                                                        dated November 3, 2022
("Purchase Agreement"). You now seek to register via post-
                                                        effective amendment the
resale of an additional 2 million common shares that may be
                                                        issued to White Lion
under the Purchase Agreement as amended in March 2023. Please
                                                        explain why you believe
you are able to do so in light of the general prohibition against
                                                        adding securities by
means of a post-effective amendment contained in Securities Act
                                                        Rule 413(a). Refer also
to Securities Act Rules Compliance and Disclosure Interpretation
                                                        Q. 210.01.
 Stephen LaMond, PharmD, MBA
Peak Bio, Inc.
August 1, 2023
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.

       Please contact Lauren Hamill at 303-844-1008 or Tim Buchmiller at
202-551-3635 with
any other questions.



                                                          Sincerely,
FirstName LastNameStephen LaMond, PharmD, MBA
                                                          Division of
Corporation Finance
Comapany NamePeak Bio, Inc.
                                                          Office of Life
Sciences
August 1, 2023 Page 2
cc:       Andrew P. Gilbert, Esq.
FirstName LastName