August 29, 2019

Glenn Mattes
President and Chief Executive Officer
TFF Pharmaceuticals, Inc.
2801 Via Fortuna, Suite 425
Austin, Texas 78746

       Re: TFF Pharmaceuticals, Inc.
           Registration Statement on Form S-1
           Filed August 20, 2019
           File No. 333-233378

Dear Mr. Mattes:

       We have reviewed your registration statement and have the following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1 filed August 20, 2019

Estimated Use of Proceeds, page 58

1.     We note your revised disclosure in response to our prior comment 12 in
our letter dated
       November 8, 2018 that your cash and cash equivalents, together with the
net proceeds of
       this offering, will be sufficient to fund the development of TFF Vori
and TFF Tac-Lac
       through the completion of their proposed Phase II studies. We also note
that you believe
       you will need to complete Phase I and Phase IIb/IIIa studies prior to
filing for marketing
       approval for TFF Tac-Lac. Please further revise your disclosure here and
elsewhere, as
       appropriate, to clarify whether you will be able to complete all
proposed clinical trials for
       TFF Tac-Lac with your cash and cash equivalents together with the net
proceeds of this
       offering. If not, please clarify how far it will allow you to proceed in
the development of
       TFF Tac-Lac and the sources of other funds needed to complete the Phase
IIb/IIIa studies
       for TFF Tac-Lac. Refer to Instruction 3 to Item 504 of Regulation S-K.
 Glenn Mattes
TFF Pharmaceuticals, Inc.
August 29, 2019
Page 2
Description of Securities, page 60

2.     Your revised disclosure on pages 25 and 65 states that your exclusive
forum provisions do
       not apply to claims under the Securities Act or the Exchange Act;
however, your amended
       bylaws and amended certificate of incorporation only carve out Exchange
Act claims from
       these provisions. If these provisions also do not apply to actions
arising under the
       Securities Act, please ensure that the provisions in your governing
documents state this
       clearly.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Christine Torney at 202-551-3652 or Mark Brunhofer at
202-551-
3638 if you have questions regarding comments on the financial statements and
related matters.
Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625
with any other
questions.



                                                           Sincerely,
FirstName LastNameGlenn Mattes
                                                           Division of
Corporation Finance
Comapany NameTFF Pharmaceuticals, Inc.
                                                           Office of Healthcare
& Insurance
August 29, 2019 Page 2
cc:       Daniel K. Donahue - Greenberg Traurig, LLP
FirstName LastName