September 23, 2024

Mitchell Glass
President and Chief Medical Officer
TNF Pharmaceuticals, Inc.
855 N. Wolfe Street, Suite 623
Baltimore, MD 21205

       Re: TNF Pharmaceuticals, Inc.
           Form 10-K
           Filed April 1, 2024
           File No. 001-36268
Dear Mitchell Glass:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K
Item 1C. Cybersecurity, page 57

1.     We note your disclosure that both your executive management team and
your board of
       directors are responsible for oversight of risks from cybersecurity
threats. Please confirm
       that in future filings you will expand upon the executive management
team's and the
       board of directors' areas of responsibility to describe their respective
processes in
       sufficient detail for a reasonable investor to understand as required by
Item 106(b)(1) of
       Regulation S-K.
2.     We note that leaders from your executive management team oversee
cybersecurity risk
       management. Please confirm that in future filings you will identify
which management
       positions or teams are responsible for assessing and managing material
risks from
       cybersecurity threats, and provide the revelant detail of all such
persons or members in
       such detail as is necessary to fully describe the nature of the
expertise as required by Item
       106(c)(2)(i) of Regulation S-K.
 September 23, 2024
Page 2

        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 Doris Stacey Gama at 202-551-3188 or Suzanne Hayes at
202-551-3675
with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences
cc:   Alla Digilova, Esq.