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                               December 11, 2020

       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. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted December
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
response.

             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
       comments.

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Prospectus Summary
       Our Portfolio, page 3

   1.                                                   We note your response
to prior comment 2 and your updated pipeline chart and reissue in
                                                        part. Please adjust the
length of the bars to reflect whether a study or a trial is ongoing or
                                                        has been completed. For
example, the bar for BT-11 for Ulcerative Colitis extends to the
                                                        end of the Phase II
column despite your disclosure elsewhere indicating that you are still
                                                        conducting the trial.
Similarly, the bar for NX-13 for Ulcerative Colitis extends to the end
                                                        of the Phase I column
despite your disclosure elsewhere indicating that you are still
                                                        conducting the trial.
Please revise your pipeline chart for each of your programs to reflect
                                                        the current clinical
development status for each product candidate.
 Josep Bassaganya-Riera
Landos Biopharma, Inc.
December 11, 2020
Page 2


Business
Our Portfolio, page 90

2.    We note your response to prior comment 6 and updated disclosure and
reissue the
      comment. You may summarize your future clinical development and
commercialization
      strategy in the text of your document, but the graphic continues to
assume regulatory
      approvals which may or may not 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 Strategy, page 95

3.    We note your response to prior comment 5 and re-issue in part. You
continue to state that
      you believe you are positioned to "accelerate" the discovery and
development of safer and
      more effective novel therapeutics and that your platform is designed to
"accelerate" the
      development of new therapeutic products. We further note your reference
on page 89 of
      your document to your strategy of "rapidly advancing" development of your
product
      candidates. Please either remove these statements or balance them to
clarify that there is
      no guarantee you will be able to "accelerate" or "rapidly advance" your
product
      candidates, that the process of clinical development is inherently
uncertain and that the
      FDA and applicable foreign regulators may not permit you to progress as
quickly as
      envisioned through the clinical, regulatory approval and
commercialization process.
NX-13, an oral NLRX1 agonist for the treatment of UC and CD, page 134

4.    We note your statement that you have completed a Phase 1 clinical trial
for NX-13 in
      normal healthy volunteers. Elsewhere, including on page 140, you state
that you are
      "currently conducting" a Phase 1 clinical trial of NX-13 in normal
healthy volunteers.
      Please reconcile your disclosure. To the extent your Phase 1 trial of
NX-13 is ongoing,
      please also adjust the bars in your pipeline chart so that they do not
extend to the end of
      the Phase I column.
       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
December 11, 2020 Page 2
cc:       Eric Blanchard
FirstName LastName