December 16, 2024

Erik Emerson
Chief Executive Officer
Apimeds Pharmaceuticals US, Inc.
2 East Broad Street 2nd Floor
Hopewell, NJ 08425

       Re: Apimeds Pharmaceuticals US, Inc.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed December 9, 2024
           File No. 333-282324
Dear Erik Emerson:

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

        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.

Amendment No. 2 to Registration Statement on Form S-1
Principal Stockholders, page 108

1.     We note your revisions to the Principal Stockholders table on page 108.
Please further
       revise the footnotes to the table to identify the natural person(s) who
have sole or
       shared voting or investment power for the securities beneficially owned
by Inscobee
       Inc., Dominus IB, Inc., and Busan Equity Partners Co., LTD. For
reference, refer
       to Item 403 of Regulation S-K.
       Please contact Eric Atallah at 202-551-3663 or Lynn Dicker at
202-551-3616 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Crawford at 202-551-7767 or Laura Crotty at 202-551-7614 with
any other
questions.
 December 16, 2024
Page 2



                       Sincerely,

                       Division of Corporation Finance
                       Office of Life Sciences
cc:   David Mannheim