April 30, 2025

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

       Re: Apimeds Pharmaceuticals US, Inc.
           Post-Effective Amendment No. 1 to Registration Statement on Form S-1
           Filed April 17, 2025
           File No. 333-282324
Dear Erik Emerson:

       We have reviewed your post-effective amendment and have the following
comments.

        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.

Post-Effective Amendment No. 1 to Registration Statement on Form S-1
Risk Factors
We have identified material weaknesses in our internal control over financial
reporting...,
page 13

1.     You state that you are not required to make a formal assessment of the
effectiveness
       of your internal control over financial reporting. However, we note that
in your Form
       10-K for the fiscal year ended December 31, 2024, you did assess the
effectiveness of
       your internal control over reporting and management concluded that your
internal
       control over financial reporting was not effective. Please revise your
risk factor to
       properly disclose that management did undertake an assessment of
internal control
       over financial reporting as of December 31, 2024, and determined that
your internal
       control was not effective as of December 31, 2024.
 April 30, 2025
Page 2
Financial Statements
Note 2 - Basis of Presentation and Summary of Significant Accounting Policies
Segment Information, page F-9

2.     You disclose on page F-12 that you adopted ASU No. 2023-07 - Segment
Reporting
       (ASC 280) for the fiscal year ended December 31, 2024. Explain how you
have
       complied with the disclosure requirements of FASB ASC paragraphs
280-10-50-20
       through 26C and 280-10-55-15D through 15F, and revise as necessary.

        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 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.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences
cc:   David Mannheim, Esq.