August 12, 2019

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

       Re: TFF Pharmaceuticals, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted July 17, 2019
           CIK No. 0001733413

Dear Mr. Mattes:

      We have reviewed your amended draft registration statement and have the
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

Draft Registration Statement on Form S-1 submitted July 17, 2019

Our Business
TFF Vori - For the Treatment of Invasive Pulmonary Aspergillosis, page 32

1.     We note your disclosure on page 33 that previous third-party studies
report that inhaled
       Voriconazole has been "effective" as a therapy in humans. Findings of
efficacy are
       determinations that are solely within the authority of the FDA. Please
delete or revise this
2.     We note your added disclosure that you have completed a 28-day toxicity
study in rats and
       a 14-day study in dogs. Please disclose the material results and data
from these studies.
 Glenn Mattes
FirstName LastNameGlenn Mattes
TFF Pharmaceuticals, Inc.
Comapany NameTFF Pharmaceuticals, Inc.
August 12, 2019
August 12, 2019 Page 2
Page 2
FirstName LastName
Other Potential Dry Powder Products, page 35

3.       We note your statement that CBD is "recognized for the treatment of
various epilepsy
         syndromes as well as anxiety, insomnia, and different types of pain,"
and that the "broader
         class of cannabinoids are believed to be additionally beneficial for
         symptoms of multiple sclerosis, anorexia, schizophrenia, and other
conditions." Please
         revise your disclosure to clarify that the FDA must approve any CBD
products that are
         marketed for therapeutic uses, and that aside from Epidiolex, there
are no other FDA-
         approved drug products that contain CBD.
4.       Please add risk factor discussion of the regulatory environment
surrounding CBD
         products, including how it would impact your business. In particular,
please address the
         impact of the Controlled Substances Act of 1970 and the Agriculture
Improvement Act of
         2018 on your development plans.
Description of Securities, page 60

5.       We note your revised disclosure regarding the exclusive forum
provisions in your
         governing documents. Please also disclose whether the provisions apply
to actions arising
         under the Securities Act. If so, please also state that there is
uncertainty as to whether a
         court would enforce such provisions and that investors cannot waive
compliance with the
         federal securities laws and the rules and regulations thereunder. In
that regard, we note
         that Section 22 of the Securities Act creates concurrent jurisdiction
for federal and state
         courts over all suits brought to enforce any duty or liability created
by the Securities Act
         or the rules and regulations thereunder. If these provisions do not
apply to actions arising
         under the Securities Act, please also ensure that the exclusive forum
provisions in your
         governing documents state this clearly. In addition, we note that the
exclusive forum
         provisions in your governing documents provide that if no state court
located within the
         State of Delaware has jurisdiction, the federal district court for the
District of Delaware
         shall be the exclusive forum. Please reflect this in your disclosure.
        You may contact Christine Torney at 202-551-3652 or Mark Brunhofer at
if you have questions regarding comments on the financial statements and
matters. Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at
202-551-3625 with
any other questions.


                                                               Division of
Corporation Finance
                                                               Office of
Healthcare & Insurance
cc:      Daniel K. Donahue - Greenberg Traurig, LLP