United States securities and exchange commission logo





                              October 1, 2020

       Greg Duncan
       Chief Executive Officer
       Virios Therapeutics, LLC
       44 Milton Avenue
       Alpharetta, GA 30009

                                                        Re: Virios
Therapeutics, LLC
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed September 25,
2020
                                                            File No. 333-248447

       Dear Mr. Duncan:

               We have reviewed your amended registration statement and have
the following
       comment. 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 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 the comment, we may have additional comments.

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

       Cover Page

   1.                                                   Your footnotes to the
fee table indicate that you are calculating your registration fee based
                                                        on Rule 457(o).
However, based on your revised disclosure that you anticipate your
                                                        offering price could be
up to $11.00 per share, it does not appear you have calculated the
                                                        registration fee based
on the maximum aggregate offer price. Please revise your fee table
                                                        accordingly.
 Greg Duncan
Virios Therapeutics, LLC
October 1, 2020
Page 2

        You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at
202-551-3494
if you have questions regarding comments on the financial statements and
related matters. Please
contact Jason Drory at 202-551-8342 or Dorrie Yale at 202-551-8776 with any
other questions.



                                                           Sincerely,
FirstName LastNameGreg Duncan
                                                           Division of
Corporation Finance
Comapany NameVirios Therapeutics, LLC
                                                           Office of Life
Sciences
October 1, 2020 Page 2
cc:       Darrick M. Mix, Esq.
FirstName LastName