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                           June 17, 2022

       Thomas Hallam
       Chief Executive Officer
       Palisade Bio, Inc.
       5800 Armada Drive, Suite 210
       Carlsbad, CA 92008

                                                        Re: Palisade Bio, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 14, 2022
                                                            File No. 333-265570

       Dear Dr. Hallam:

              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 Dorrie
Yale at 202-551-8776 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Life Sciences
       cc:                                              Karen Deschaine, Esq