United States securities and exchange commission logo





                             March 17, 2021

       Shalabh Gupta, M.D.
       Chief Executive Officer, President and Chairman
       Unicycive Therapeutics, Inc.
       5150 El Camino Real, Suite A-32
       Los Altos, CA 94022

                                                        Re: Unicycive
Therapeutics, Inc.
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted February
18, 2021
                                                            CIK No. 0001766140

       Dear Dr. Gupta:

             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 submitted
February 18, 2021

       Background on Renazorb, page 52

   1.                                                   We note your statement
here and on page 53 that "Renazorb was minimally absorbed to
                                                        the systemic
circulation and was safe...." Please revise these and all similar statements
                                                        throughout your
prospectus that state or imply that your product candidates are safe or
                                                        effective as these
determinations are solely within the authority of the FDA and
                                                        comparable regulatory
bodies.
       General

   2.                                                   We note your response
to prior comment 4 and reissue. The pipeline table on page 49 and
                                                        on your website
indicates that Renazorb has completed Phase 3 clinical trials. However,
 Shalabh Gupta, M.D.
Unicycive Therapeutics, Inc.
March 17, 2021
Page 2
      we note your disclosure on page 1 that "Spectrum conducted a Phase 1
clinical trial with
      Renazorb in 2012 prior to the grant of [your] license in 2018." To the
extent that you
      have completed Phase 2 and 3 clinical trials, please include disclosure
that complies with
      prior comment 3. Otherwise, revise the pipeline table on page 49 and on
your website to
      illustrate the product candidate's current status.
       You may contact Ibolya Ignat at 202-551-3636 or Brian Cascio at
202-551-3676 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jeffrey Gabor at 202-551-2544 or Celeste Murphy at 202-551-3257 with
any other
questions.



                                                           Sincerely,
FirstName LastNameShalabh Gupta, M.D.
                                                           Division of
Corporation Finance
Comapany NameUnicycive Therapeutics, Inc.
                                                           Office of Life
Sciences
March 17, 2021 Page 2
cc:       Jeffrey Fessler, Esq.
FirstName LastName