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U.S. Securities and Exchange Commission
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Re:

Tyra Biosciences, Inc.

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

Submitted July 2, 2021

CIK No. 0001863127

Dear Mr. Hagius:

We are in receipt of the Staff’s letter dated July 13, 2021 with respect to the above-referenced confidential draft amended Registration Statement (the “Amended Draft Registration Statement”). We are responding to the Staff’s comments on behalf of Tyra Biosciences, Inc. (“Tyra” or the “Company”) as set forth below. Simultaneously with the submission of this letter, the Company is publicly filing via EDGAR the Registration Statement on Form S-1 (the “Registration Statement”) responding to the Staff’s comments and updating the Amended Draft Registration Statement.

The Company’s responses set forth in this letter are numbered to correspond to the numbered comments in the Staff’s letter. All terms used but not defined herein have the meanings assigned to such terms in the Registration Statement. For ease of reference, we have set forth the Staff’s comments and the Company’s response for each item below.

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

Risk Factors

Changes in methods of product candidate manufacturing or formulation may result in additional costs or delay., page 29

We note your amended disclosure that you “intend to change the delivery vehicle we use in our formulation for TYRA-300 from polyethylene glycol 400 to a cyclodextrin based vehicle” and that “[t]his change in formulation may result in effects and results that are different from those observed in our completed preclinical studies to date.” Please provide more information about this change in a relevant portion of your business section and explain whether you believe your comparisons to erdafitinib and pemigatinib, which you previously addressed in response to comment number 7, are still appropriate.