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                                                              February 26, 2025

George Magrath
Chief Executive Officer
Opus Genetics, Inc.
8 Davis Drive, Suite 220
Durham, NC 27709

       Re: Opus Genetics, Inc.
           Registration Statement on Form S-3
           Filed February 18, 2025
           File No. 333-285038
Dear George Magrath:

       We have conducted a limited review of your registration statement 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.

Registration Statement on Form S-3
Cover Page

1.     We note your disclosure on the cover page that this prospectus relates
to "the issuance
       by [you] of up to 19,382,437 shares of [y]our common stock" and that you
will "not
       receive any proceeds from the issuance or sale of shares of Common Stock
pursuant
       to this prospectus." Please revise your cover page to clarify that this
offering relates to
       a resale of shares of common stock by the selling securityholders.
General

2.     Please revise to include financial statements for the fiscal year ended
December 31,
       2024 or advise.
 February 26, 2025
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Joshua Gorsky at 202-551-7836 or Joe McCann at
202-551-6262 with
any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Andrea Reed
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