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                          June 30, 2020

       Teofilo Raad
       Chief Executive Officer and President
       Pulmatrix, Inc.
       99 Hayden Avenue, Suite 390
       Lexington, MA 02421

                                                        Re: Pulmatrix, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 25, 2020
                                                            File No. 333-239431

       Dear Mr. Raad:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Alan
Campbell at 202-551-4224 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Rick A. Werner, Esq.