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United States securities and exchange commission logo





                           September 27, 2021

       Ilya Rachman
       Chief Executive Officer
       Immix Biopharma, Inc.
       11400 West Olympic Blvd., Suite 200
       Los Angeles, CA 90064

                                                        Re: Immix Biopharma,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 17,
2021
                                                            File No. 333-259591

       Dear Dr. Rachman:

              We have reviewed your registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

       Form S-1 filed September 17, 2021

       Prospectus Summary, page 1

   1.                                                   We refer to the second
and third rows in your pipeline table under the heading IMX-111
                                                        and IMX-120. In light
of your disclosure that you plan to conduct IND-enabling studies
                                                        for IMX-111 and IMX-120
by mid-2022, please shorten the arrows in these rows to show
                                                        that you have not yet
completed the preclinical trials.
 Ilya Rachman
FirstName LastNameIlya
Immix Biopharma,  Inc. Rachman
Comapany 27,
September NameImmix
              2021     Biopharma, Inc.
September
Page  2   27, 2021 Page 2
FirstName LastName
AxioMx Master Services Agreement, page 51

2.       We note your response to our prior comment 9 and your disclosure on
page 51 that the
         term of the AxioMx Master Services Agreement was set to expire on
December 22, 2019,
         unless extended by you and AxioMx. Please revise to include disclosure
of any
         extensions and/or amendments to the Master Services Agreement and file
any
         amendments as exhibits.
        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.

       You may contact Gary Newberry at 202-551-3761 or Al Pavot at
202-551-3738 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jane Park at 202-551-7439 or Laura Crotty at 202-551-7614 with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:      Jeffrey Fessler, Esq.
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