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                                                             July 17, 2024

Jun Liu
Chief Executive Officer
Curanex Pharmaceuticals Inc
2 Jericho Plaza, Suite 101B
Jericho, NY 11753

       Re: Curanex Pharmaceuticals Inc
           Draft Registration Statement on Form S-1
           Submitted June 20, 2024
           CIK No. 0002025942
Dear Jun Liu:

       We have reviewed your 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.

Draft Registration Statement on Form S-1
Cover Page

1.     Please clarify on the cover page whether you intend to take advantage of
the controlled
       company exemptions under the Nasdaq rules.
Prospectus Summary
Corporate History and Recent Development, page 1

2.     You state that you entered into a Subscription Agreement on April 15,
2024 with an
       investor. Please identify the investor and disclose the expected price
per share to be paid.
Business Overview, page 2

3.     You state that your lead product candidate, Phyto-N, has demonstrated
promising efficacy
       in animal models and has a long history of safe use in traditional
medicine. Safety and
       efficacy determinations are solely within the authority of the FDA or
comparable foreign
 July 17, 2024
Page 2

        regulator. Please revise or remove statements/inferences throughout
your prospectus that
        your product candidate is safe and/or effective. You may present
clinical trial end points
        and objective data without concluding efficacy and you may state that
your product is
        well tolerated, if accurate.
4.      You state that your lead product candidate, Phyto-N, is an extract from
a single plant.
        Please identify the plant or otherwise advise.
5.      Please balance your disclosure to discuss that although your drug
development pipeline
        encompasses seven core indications you have only conducted preclinical
studies for each.
        Further, please also discuss that you have not submitted an IND and
that you plan to
        submit an IND in 2025 and begin Phase I clinical trials in 2025 for the
treatment of
        ulcerative colitis only as you do on page 44.
Risk Factors
If we fail to raise capital when needed..., page 5

6.      You state that you have very limited revenue-producing operations. We
note that your
        single product candidate Phyto-N is in very early stages. Please
discuss, here and
        wherever else applicable, the revenue-producing operations your
business conducts.
A majority of our directors are officers and/or directors of Duraviva..., page
7

7.      You state that your Chief Executive Officer, director, and President,
Jun Liu, is also the
        President of Duraviva. Please state whether Jun Liu will be working as
CEO on a non-full
        time basis. If so, please revise your disclosure to clearly state Jun
Liu's time commitment
        to the company and include an appropriate risk factor.
We are dependent on our collaborative agreements..., page 7

8.      You state that you currently rely, and will in the future rely, on
collaborative agreements
        with third parties. Please identify your current collaborative
agreements and disclose the
        material terms of those agreements and attach them as exhibits or
otherwise advise. Refer
        to Item 601(b)(10) of Regulation S-K for guidance.
Risk Related to Ownership of Our Securities, page 13

9.      We note that you anticipate that the Offering will be approximately in
the range of $5
        million to $30 million. Given the relatively small size of your
offering, please include a
        separate risk factor addressing the potential for rapid and substantial
price volatility and
        any known factors particular to your offering that may add to this risk
and discuss the
        risks to investors when investing in stock where the price is changing
rapidly. Clearly
        state that such volatility, including any stock-run up, may be
unrelated to your actual or
        expected operating performance and financial condition or prospects,
making it difficult
        for prospective investors to assess the rapidly changing value of your
stock.
Use of Proceeds, page 20

10.     Please revise your use of proceeds section to provide the approximate
dollar amount
        intended to be used for each purpose listed.
11.     You state that you plan to use the net proceeds from this offering to
initiate Phase I or
        proof-of-concept Phase II trials in inflammatory diseases, among other
things. Please
 July 17, 2024
Page 3

       specify if this relates to your product candidate Phyto-N, how far in
the development
       process you expect to reach with the proceeds of the offering, and the
specific
       inflammatory diseases you plan to pursue.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 25

12.    You state that during fiscal year ended December 31, 2022 you generated
$26,000 from
       related party transactions including $21,571 for costs of goods sold and
sales of
       supplement products. Please identify the supplemental products and
discuss if you plan to
       continue the sale of such products.
Business
Market Opportunities for Phyto-N, page 28

13.    You state that in clinical practice, Phyto-N has shown the ability to
cure certain diseases,
       such as ulcerative colitis, and maintain long-term remission, offering a
significant
       advantage over existing therapies that often require continuous
treatment. Please discuss
       your basis in claiming that Phyto-N has the ability to cure certain
diseases. We also note
       your reference to the robust clinical experience of Phyto-N in China, if
Phyto-N has been
       approved in other jurisdictions please state so, if not please remove
such statements.
14.    You state that you are actively identifying and isolating the active
chemical compounds
       responsible for the therapeutic effects. Please identify these
compounds.
15.    You state that a key competitive advantage is that Phyto-N is
well-positioned for an
       accelerated development and regulatory pathway in the US. Please expand
your
       discussion to explain how clinical experience in China and FDA approval
of other
       botanical drugs will accelerate your development process. Further, with
a view to
       disclosure, please tell us how many botanical drug products to date have
received FDA
       approval. To the extent that only a limited number of botanical drug
products are FDA
       approved, please revise this section to disclose this information and
similarly highlight
       this information in the Summary to convey the novelty and/or challenges
of receiving
       approval for a botanical drug.
Product Pipelines, page 29

16.    You state that Phyto-N is an alternative for patients with moderate to
severe ulcerative
       colitis as it addresses limitations of current treatments. Please
identify the limitations of
       the current treatments.
Market analysis of inflammatory bowel disease (IBD) treatment..., page 30

17.    We note your market projections here and for each indication you intend
to pursue. Given
       the lengthy timeline and uncertainty with regard to clinical
development, please remove
       these estimated and projected market values as they appear to be
premature and
       speculative given your stage of development.
Market Potential of Phyto-N IBD and Target Market, page 31

18.    You state that your initial target market for Phyto-N for IBD could be
Asia where clinical
       observations and animal studies were conducted and expansion into other
major IBD
 July 17, 2024
Page 4

       markets would require additional clinical trials and regulatory
approvals. Please clarify if
       you have performed clinical trials in Asia, if so, specify the country,
and discuss if you
       received regulatory approval of your product.
19.    You state that your results highlight the promising therapeutic effects
of Phyto-N on
       various autoimmune diseases. Please discuss the results referenced.
20.    You state that the actual market value may vary depending on factors
such as the
       company's profitability, growth prospects, competition, and investor
sentiment. Please
       balance your disclosure and include a discussion that there is no
guarantee that your
       product candidate will be approved.
Market Analysis of Nonalcoholic Fatty Liver Disease (NAFLD) Treatments..., page
37

21.    You state that there are over 40 drugs in development for NASH, that
there are currently
       two late-stage drugs, and that the FDA recently approved the first drug
for NASH,
       Madrigal, on March 14, 2024. Please include a discussion that although a
drug has been
       approved and there are other late-stage drugs, this is not an indication
that your product
       will receive regulatory approval and that your product candidate is a
botanical drug and as
       such may face different challenges as it goes through the regulatory
process.
22.    You state that Phyto-N boasts superior anti-inflammatory properties and
unlike recently
       FDA approved Rezdiffra, Phyto-N mitigates inflammation occurrence
without causing
       adverse reaction, such as diarrhea, nausea, and potential liver enzyme
elevations. Please
       discuss your basis for such claims.
23.    You state that Phyto-N has dual preventive and therapeutic benefits and
potentially better
       safety profile when compared to the newly approved drug Rezdiffra.
Please discuss if you
       have conducted head-to-head studies. If not, please remove such
comparisons as you do
       not have the basis to compare your candidate to other products.
Our Growth Strategy, page 42

24.    You state that the successful completion of clinical trials would
position Phyto-N as a
       potential first-in-class botanical drug. Please remove references
throughout your
       prospectus to potential "first-in-class" when describing your product
candidate as these
       descriptions imply an expectation of regulatory approval and are
inappropriate given the
       length of time and uncertainty with respect to securing marketing
approval.
Intellectual Property, page 43

25.    Please revise here and elsewhere in the prospectus, where appropriate,
to explain what
       a provisional patent application is and how it differs from a
nonprovisional patent
       application. Revise the table and your risk factor disclosure to
disclose the expiration
       dates of the provisional patents and the risks associated with not
having patent coverage
       for the work you are conducting.
26.    We note your table on page 43 listing your provisional patent
applications. Please
       identify the applicable jurisdiction for the Plant Extract Compositions
and Uses Thereof
       For Treating Acne.
 July 17, 2024
Page 5
Our Business Plan, page 44

27.    You state that you have conducted animal pharmacology studies to
demonstrate efficacy
       in relevant disease models. Please identify the disease models.
Our Revenue Model, page 45

28.    You state that you anticipate that Curanex's revenue streams will
primarily derive from
       commercialization of your botanical drug products through product sales
and
       collaboration and licensing agreements. Please balance your disclosure
by including a
       discussion that your product candidate, Phyto-N, is in pre-clinical
studies and that
       although you plan to file an IND in 2025 there is no guarantee that you
will receive
       regulatory approval and reach commercialization. Please also identify
and quantify the
       research grants and contracts you have received to date.
Research and Development (FDA Related Application)
Moderate to Severe Ulcerative Colitis
Human Application Case, page 45

29.    We note your discussion of a patient with ulcerative colitis who took
Phyto-N
       orally. Please discuss where this case took place and if Phyto-N has
been clinically
       approved in any jurisdiction. Please also balance the case study to
indicate that Phyto-N
       is in the early stages of pre-clinical development, that it will take
many years to
       commercialize this product candidate and that there can be no guarantee
that Phyto-N will
       achieve similar results in clinical testing.
Animal Experiment Research, page 46

30.    You state that the Disease Activity Index (DAI) was significantly lower
in the Phyto-N
       group by day 14 of the treatment and continued to improve until the end
of the study.
       Please identify the scores referenced and discuss the significance of
such results.
31.    We note Figure 1 includes a reference to p-values in Note D. Please
define the term at
       first use and discuss the significance of the p-value results shown.
32.    With respect to the figures, tables, and graphics included throughout
this section, please
       revise your tables or graphics to ensure that the text in each,
including subscript or other
       notations, are large enough and clearly legible and that each includes a
discussion of the
       significance of each result presented.
33.    We note your discussion of the results from previously conducted animal
studies for
       ulcerative colitis and the other seven indications you plan to pursue.
Please discuss here,
       and for each indication, where each study was conducted and if there
were any adverse or
       severe adverse events observed.
Regulation, page 64

34.    Please revise your discussion of FDA regulation and product approval to
address
       regulatory issues and technical challenges that are unique to botanical
drug products as
       compared to nonbotanical drugs and include any appropriate risk factors.
In this regard,
       we refer to the information contained in FDA   s    Botanical Drug
Development: Guidance
       for Industry    available at:
https://www.fda.gov/files/drugs/published/Botanical-Drug-
       Development--Guidance-for-Industry.pdf
 July 17, 2024
Page 6

35.    You state that the FDA has established special provisions for botanical
drugs that have a
       long history of safe human use. Please discuss the special provisions
referenced or
       otherwise remove such statement.
Executive Compensation, page 74

36.    You state that for fiscal years ended December 31, 2023 and 2022, the
Company did not
       make any compensation to Dian Ying Jin. Please clarify if there were any
other executive
       officers during fiscal years ended December 31, 2023 and 2022 that
received
       compensation.
Certain Relationship and Related Party Transactions, page 77

37.    You state that Duraviva transferred and assigned to you all of its IP
assets together with
       $730,000 consideration. Please identify all assets that were transferred
to you as part of
       the asset purchase agreement as you do on page 25.
General

38.    Please provide us with supplemental copies of all written
communications, as defined in
       Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
       have presented or expect to present to potential investors in reliance
on Section 5(d) of the
       Securities Act, whether or not you retained, or intend to retain, copies
of those
       communications.
       Please contact Christine Torney at 202-551-3652 or Daniel Gordon at
202-551-3486 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Doris Stacey Gama at 202-551-3188 or Chris Edwards at 202-551-6761 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences
cc:   Joe Laxague, Esq.
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