August 5, 2025

Mitchell Glass
President and Chief Medical Officer
TNF Pharmaceuticals, Inc.
855 N. Wolfe Street, Suite 623
Baltimore, MD 21205

       Re: TNF Pharmaceuticals, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2024
           File No. 001-36268
Dear Mitchell Glass:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Part I
Item 1. Business
Drug Development, page 6

1.     In future filings, please ensure that your pipeline table accurately
reflects the current
       stages of your trials. For example, you state on page 7 that you still
need to "[e]xecute
       on IND-enabling studies of Supera-CBD to enable submission of an IND for
a Phase
       1 clinical trial." Please shorten the arrows for Supera-CBD given
preclinical trials
       appear to be ongoing and not completed. In addition, you state on page
29 that you
       plan "to launch a Phase 2b clinical trial of isomyosamine   s efficacy
in sarcopenia
       early in the first quarter of 2025." Please shorten the arrow for MYMD1
for
       sarcopenia given it appears that Phase 2 trials are not complete and
still ongoing.
 August 5, 2025
Page 2
Isomyosamine
Overview, page 7

2.     In future filings, please revise your disclosures on page 7 to remove
the statements
       that Isomyosamine showed    safety    in a Phase 2 clinical trial in
sarcopenia as safety
       determinations are within the sole authority of the FDA and similar
foreign regulators.
       We advise you that you may present the objective data from pre-clinical
and clinical
       trials without drawing a conclusion from the results. For example, if
true, you may
       note that a candidate was well tolerated, the absence of serious adverse
events or the
       number of trial participants who met the identified trial endpoints.
3.     We note your disclosure you "completed a 28-day Phase 2 trial for
sarcopenia."
       However, your business section does not appear to describe the design of
the trial and
       objective results. In future filings, please describe the completed
Phase 2 trial in
       greater detail. Your discussion should identify the number of
participants, trial
       endpoints, the objective results, the p-values and statistical
significance of the
       results. In addition, to the extent that any participants experienced
any serious adverse
       events, please describe them and quantify the number of each type of
event.
Assignment and Royalty Agreements, page 16

4.     In future filings, please revise to disclose the term and terminations
provisions of the
       Amended and Restated Confirmatory Patent Assignment and Royalty
Agreements
       with SRQ Patent Holdings and SRQ Patent Holdings II. In addition, please
disclose
       the specific product candidate(s) to which the agreements relate.
Intellectual Property, page 16

5.     In future filings, please revise your intellectual property disclosure
to clearly identify:
       (i) each of your material patents (rather than stating that you have a
certain number of
       patents), (ii) the material product candidate(s) dependent on each
material patent, (iii)
       whether the patent is owned or licensed, (iv) the type of patent
protection (e.g.,
       composition of matter, use, or process) and (v) the expiration dates for
each patent
       discussed. In this regard it may be useful to provide tabular
disclosure.

        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 Daniel Crawford at 202-551-7767 or Jason Drory at
202-551-8342 if
you have questions regarding the comments or related matters.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences
cc:   Rick Werner, Esq