October 2, 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 Registration Statement on Form S-1 Filed September 27, 2019 File No. 333-233378 Dear Mr. Mattes: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Amendment No. 1 to Form S-1 filed September 27, 2019 Exhibits 1. Please provide an opinion of counsel that addresses whether the warrants constitute a binding obligation of the issuer under the law of the jurisdiction governing the warrants. For guidance, please refer to Section II.B.1.f of Staff Legal Bulletin No. 19. 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, Division of Corporation Finance Office of Life Sciences cc: Daniel K. Donahue - Greenberg Traurig, LLP