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                                                            July 3, 2025

Chris Kim
Chief Executive Officer
Liminatus Pharma, Inc.
6 Centerpointe Drive #625
La Palma, CA 90623

       Re: Liminatus Pharma, Inc.
           Registration Statement on Form S-1
           Filed June 24, 2025
           File No. 333-288289
Dear Chris Kim:

       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-1
General

1.     We note that you are registering 1,750,000 shares of common stock
issuable to Cantor
       in settlement of $7.0 million of deferred underwriter fees. Please
revise, wherever
       appropriate, to explain how the number of shares issuable to Cantor was
calculated. In
       this regard, we note that the amendment to your Form S-4 filed on August
9, 2024
       indicated that 700,000 shares would be issuable to Cantor in settlement
of these
       deferred underwriting fees, subject to adjustment based on the five day
volume-
       weighted average price prior to the filing of a resale registration
statement covering
       such shares, and it appears that your shares traded above $10.00 per
share during that
       period.
2.     Please revise to include pro forma condensed combined financial
information showing
       the impact of the consummation of the Business Combination and the other
events
 July 3, 2025
Page 2

       contemplated by the Business Combination Agreement for the period ended
March
       31, 2025 as you have in the amended Form 8-K filed June 2, 2025 or
otherwise
       advise.
        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 Tyler Howes at 202-551-3370 or Tim Buchmiller at
202-551-3635
with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Giovanni Caruso, Esq.
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