View:
United States securities and exchange commission logo





                               January 29, 2021

       Josep Bassaganya-Riera
       Chairman, President and Chief Executive Officer
       Landos Biopharma, Inc.
       1800 Kraft Drive, Suite 216
       Blacksburg, VA 24060

                                                        Re: Landos Biopharma,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed January 28,
2021
                                                            File No. 333-252083

       Dear Dr. Bassaganya-Riera:

              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.

       Amendment No. 1 to Registration Statement on Form S-1

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your response
to prior comment 1 and your updated disclosure which states, in
                                                        part, that your
clinical trial was conducted to "demonstrate" the safety and efficacy of BT-
                                                        11. Safety and efficacy
are determinations that are solely within the purview of the FDA
                                                        and foreign regulators.
Please revise your statement here and in Business to remove any
                                                        implication that the
Phase 2 trial of BT-11 demonstrated safety and efficacy.

                                                        We further note your
statement that the Phase 2 trial was not conducted to establish
                                                        statistical
significance, but rather to inform the design of the Phase 3 trial. Your
disclosure
                                                        on page 111 indicates
that goal of the Phase 2 trial was to establish the safety and efficacy
 Josep Bassaganya-Riera
Landos Biopharma, Inc.
January 29, 2021
Page 2
      of BT-11. Please reconcile your disclosure here and in Business.
Alternatively, please
      remove this portion of the newly-added disclosure.
Condensed consolidated statement of operations and comprehensive loss, page
F-25

2.    Please revise the earnings per share calculation presented here to
reflect the 1.8249-for-1
      stock split consistent with the disclosure on page F-37. In this regard,
ensure that the stock
      split has been retroactively applied throughout the document in every
instance in
      consideration of SAB Topic 4C.
        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 Jenn Do at 202-551-3743 or Kevin Kuhar at 202-551-3662
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Alan Campbell at 202-551-4224 or Chris Edwards at 202-551-6761 with any other
questions.



                                                             Sincerely,
FirstName LastNameJosep Bassaganya-Riera
                                                             Division of
Corporation Finance
Comapany NameLandos Biopharma, Inc.
                                                             Office of Life
Sciences
January 29, 2021 Page 2
cc:       Eric Blanchard
FirstName LastName