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                          January 9, 2024

       Amit Etkin
       Chief Executive Officer
       Alto Neuroscience, Inc.
       369 South San Antonio Road
       Los Altos, CA 94022

                                                        Re: Alto Neuroscience,
Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted December
28, 2023
                                                            CIK No. 0001999480

       Dear Amit Etkin:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional comments.

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

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your response
to prior comment 3, which we reissue in part.
                                                            Please describe,
where appropriate, each of the discussions you have had with the
                                                           FDA regarding your
novel approach to the discovery and development of your
                                                           product candidates
using your Platform, as well as any material outcomes of such
                                                           discussions.
                                                            Explain whether you
are basing your current expectation that you may be required to
                                                           develop and obtain
FDA approval of a companion diagnostic for any of your product
                                                           candidates upon your
prior discussions with the FDA. Also, please describe when
                                                           you expect to know
more definitively the FDA's views on this subject and how such
                                                           views may affect
your plans.
 Amit Etkin
FirstName  LastNameAmit Etkin
Alto Neuroscience, Inc.
Comapany
January    NameAlto Neuroscience, Inc.
        9, 2024
January
Page 2 9, 2024 Page 2
FirstName LastName
2.       We note your revisions in response to prior comment 5, which we
reissue. Please further
         revise the disclosure on pages 1, 103, and 123 to include the
information contained in your
         response to prior comment 5 in your letter dated December 28, 2023
concerning your goal
         to ultimately provide treatments, if approved, that are tailored to
specific patient
         populations and explain how this might allow you to avoid the current
lengthy paradigm
         of treating psychiatric patients.
Our Pipeline, page 3

3.       We note your revisions in response to prior comment 7, which we
reissue in part. Please
         revise your disclosure on pages 4, 104, and 125 to clarify whether or
not the Company's
         representatives have had any interaction to date with the FDA
regarding its willingness to
         accept foreign clinical trial data underpinning the recently submitted
IND covering
         ALTO-203 in MDD. Also, please revise the Prospectus Summary to
disclose the risk that
         the FDA or comparable regulators may not accept earlier clinical data
generated abroad,
         in which case you may need to conduct additional clinical trials, as
referenced in your risk
         factor on page 31.
4.       We note your revisions in response to prior comment 13, which we
reissue in part. Please
         further revise your discussion of the clinical development of your
ALTO-202 program
         here and in the Business section where appropriate to disclose the
following information
         with respect to any material clinical trials that third parties
conducted:
             the trial design;
             the number of participants in the trial;
             the primary and secondary endpoints as well as the results as they
relate to those
              endpoints; and
             the occurrence of any serious adverse events.

         Additionally, please include a description of any material development
activities you have
         conducted to date since licensing ALTO-202, relevant clinical work
conducted or in
         process, and the remaining steps to develop and commercialize the
product and disclose
         when you plan to initiate a Phase 2 trial for ALTO-202 and expect to
report data from that
         trial.
Risk Factor Summary, page 8

5.       Consistent with your disclosure on page 162 and elsewhere, please
revise your summary
         risk and risk factor disclosure where appropriate to highlight that
issued patents covering
         the composition of ALTO-202 are due to retire in 2024 (compound) and
2035
         (polymorph) and patents covering the composition of ALTO-203 in 2027.
Business
ALTO-101 Biological Rationale, page 151

6.       We note your response stating that you have revised disclosure on page
152 to ensure that
         the graphics included are legible. However, we observe that the
revisions are not sufficient
 Amit Etkin
Alto Neuroscience, Inc.
January 9, 2024
Page 3
      to render your disclosures easily readable without magnification, as
certain text remains
      too small to be clear. Please further review and revise as appropriate.
       Please contact Li Xiao at 202-551-4391 or Mary Mast at 202-551-3613 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Lauren Hamill at 303-844-1008 or Tim Buchmiller at 202-551-3635 with any other
questions.



                                                           Sincerely,
FirstName LastNameAmit Etkin
                                                           Division of
Corporation Finance
Comapany NameAlto Neuroscience, Inc.
                                                           Office of Life
Sciences
January 9, 2024 Page 3
cc:       Divakar Gupta
FirstName LastName