United States securities and exchange commission logo

                              September 15, 2020

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

                                                        Re: Landos Biopharma,
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted September
1, 2020
                                                            CIK No. 0001785345

       Dear Dr. Bassaganya-Riera:

             We have reviewed your amended draft 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 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 our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 1 to Draft Registration Statement on Form S-1 submitted
September 1, 2020

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your response
to prior comment 1 and continue to object to your statements that
                                                        you are focused on
developing "first-in-class" therapeutics and that your therapeutics are
"first-in-class." The qualifiers "if effective and approved" and "whereby our
                                                        product candidates use
unique and new mechanisms of action" do not address our
                                                        concerns that
"first-in-class" continues to imply (i) that your product candidates will be
                                                        effective and (ii) your
product candidates are likely to be the first treatments available,
                                                        neither of which is
appropriate at this stage of development. Please revise your
                                                        registration statement
to remove the phrase "first-in-class."
 Josep Bassaganya-Riera
FirstName LastNameJosep
Landos Biopharma,  Inc. Bassaganya-Riera
Comapany 15,
September NameLandos
              2020     Biopharma, Inc.
Page 2    15, 2020 Page 2
FirstName LastName

         You may state, if accurate, that your product candidates are the first
orally administered
         therapeutics to target the LANCL2, NLRX1 and PLXDC2 pathways for the
treatment of
         the various indications described in the prospectus. However, you may
not state or imply
         that your product candidates will be the first products in this class
Our portfolio, page 3

2.       We note your response to prior comment 3 and updated disclosure and
reissue in part.
         Please remove the "ongoing/completed" language from your pipeline
chart and adjust the
         length of the bars to reflect whether studies or a trial is ongoing or
has been completed.
         For example, for product candidates that are currently in a Phase I
trial, you may extend
         the bar to the middle of the Phase I trial column, but not to the end.

         We further note the distinction in your chart between "preclinical"
and "IND-enabling"
         studies. As "IND-enabling" studies are preclinical, please revise your
table to eliminate
         the distinction between the preclinical and IND-enabling studies and
show preclinical
Our strengths, page 5

3.       We note your response to prior comment 7. Please revise your
disclosure throughout the
         document where the term "significant unmet medical need" is used to
clarify that you
         have not yet had conversations with the FDA regarding fast track
designation or priority
         review for your product candidates.
Our strategy, page 6

4.       We note your response to prior comment 4. Your response supports the
statements that
         you believe you are a leader in developing immunometabolic product
candidates for IBD
         and understanding the immune effects of the LANCL2 pathway. However,
your response
         does not support the claim that you are a leader in the broader field
         immunometabolism, please revise your disclosure to remove this claim.
5.       We note your response to prior comment 5 and reissue the comment. Your
         continues to state that you intend to "rapidly advance" your product
candidates and to
         "accelerate" the discovery and development of therapeutics for
autoimmune diseases.
         Please revise this disclosure and similar disclosure throughout the
prospectus to remove
         any implication that you will be successful in commercializing your
product candidates in
         a rapid or accelerated manner as such statements are speculative.
Our Portfolio, page 89

6.       Please remove the new pipeline graphic that you have inserted at the
end of "Our
         portfolio" introduction. The graphic assumes regulatory approvals
which may or may not
 Josep Bassaganya-Riera
Landos Biopharma, Inc.
September 15, 2020
Page 3
      be granted and that the data from your preclinical studies and clinical
trials will permit
      you to further progress each of your product candidates.
Our strengths, page 93

7.    We note your statement that no dose-limiting toxicities have been
observed in doses up to
      7-fold higher than the currently proposed therapeutic dose for BT-11 in
completed clinical
      trials. The prospectus only references one completed clinical trial of
BT-11. Please update
      your disclosure to describe any additional clinical trials of BT-11 that
have been
      completed or revise your statement to clarify that only one trial of
BT-11 has been
Foundations of the LANCE platform, page 100

8.    We refer to prior comment 13 and note that the graphic you have added at
the top of page
      100 continues to state that your therapeutic candidates have improved
safety profiles.
      Please remove any disclosure stating or implying that your product
candidates are safe as
      that determination is within the authority of the FDA and comparable
regulatory bodies.
Consolidated balance sheets, page F-3

9.    Please revise to only present the pro forma balance sheet as of June 30,
2020, the latest
      balance sheet included in the filing. Also revise the footnote discussion
on page F-8 as
       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

FirstName LastNameJosep Bassaganya-Riera
                                                             Division of
Corporation Finance
Comapany NameLandos Biopharma, Inc.
                                                             Office of Life
September 15, 2020 Page 3
cc:       Eric Blanchard
FirstName LastName