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                                                            October 4, 2024

Anatoly Dritschilo
Chief Executive Officer
Shuttle Pharmaceuticals Holdings, Inc.
401 Professional Drive, Suite 260
Gaithersburg, MD 20879

       Re: Shuttle Pharmaceuticals Holdings, Inc.
           Registration Statement on Form S-1
           Filed September 20, 2024
           File No. 333-282231
Dear Anatoly Dritschilo:

     We have conducted a limited review of your registration statement and have
the following
comment.

       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.     Please revise your registration statement as appropriate to provide
clear and consistent
       disclosure of the nature and amount of securities being registered. In
this regard, it
       appears that you are registering units, with each unit consisting of (i)
a share of common
       stock plus a common warrant or (ii) for security holders who would
exceed 4.99%
       beneficial ownership, a pre-funded warrant plus a common warrant. It
further appears
       that, in addition to the units, you are registering the shares of common
stock issuable upon
       exercise of the pre-funded warrants and the common warrants. However,
the foregoing is
       not clear in the heading at the top of your prospectus cover page and is
not addressed until
       the fourth paragraph of the prospectus cover page. Your revised
disclosures, including the
       heading at the top of your prospectus cover page, should prominently and
clearly identify
       the types of securities, and the number of each type of security, you
are registering. Your
       revised disclosures should also clearly disclose the offering price per
unit. Refer to Items
 October 4, 2024
Page 2

       501(b)(2) and (3) of Regulation S-K. In addition to your revisions on
the prospectus cover
       page, please similarly revise your disclosures in "The Offering,"
"Description of
       Securities We are Offering," and "Plan of Distribution" sections
beginning on pages 12,
       95, and 97, respectively, as appropriate.
        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 Jessica Dickerson at 202-551-8013 or Joshua Gorsky at
202-551-7836
with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Megan J. Penick, Esq.
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