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                             September 23, 2020

       Greg Duncan
       Chief Executive Officer
       Virios Therapeutics, LLC
       44 Milton Avenue
       Alpharetta, GA 30009

                                                        Re: Virios
Therapeutics, LLC
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed September 16,
2020
                                                            File No. 333-248447

       Dear Mr. Duncan:

             We have reviewed your amended registration statement and have the
following
       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 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 11, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed September
16, 2020

       Prospectus Summary
       Phase 2b IBS Trial Holds Potential to Build IMC-1 Value as a Complement
to FM, page 5

   1.                                                   We note your response
to prior comment 1, including your revised disclosure at the top of
                                                        page 5. Please further
revise to delete the mitigating disclosure regarding the serious
                                                        adverse effect. Please
also update the text in the first paragraph of this section as it
                                                        currently continues to
refer to the deleted graphic.
       Business
       PRID-201 Phase 2a Study of IMC-1 In Patients With Fibromyalgia
(NCT01850420), page 78

   2.                                                   As previously stated in
our prior comment 7, please ensure that your narrative disclosure
 Greg Duncan
Virios Therapeutics, LLC
September 23, 2020
Page 2
      clearly explains the results in your table that is now on page 81. For
example, it does not
      appear that there is narrative discussion covering the 30% pain reduction
endpoints. Please
      also clarify if the results are not statistically significant, (or if the
studies were not
      powered for statistical significance with respect to certain endpoints),
as you state that
      IMC-1 exhibited "significant" improvements across "a full battery of
secondary
      outcomes."
Employment Agreements, page 107

3.    In your response to prior comment 13 you state Mr. Burch will resign as
President upon
      completion of the offering, but you only appear to disclose the planned
resignation of Mr.
      Burch in a footnote on page 99. Please revise your registration statement
to integrate Mr.
      Burch's planned resignation with your other disclosures. For example, on
page 5 you
      discuss your newly expanded leadership team and highlight Mr. Burch's
prior experience
      but you do not disclose that he will be resigning as your President. In
addition, on page 43
      you disclose that you are highly dependent on the development,
regulatory,
      commercialization and business development expertise of Mr. Burch, but do
not disclose
      his planned resignation. In addition, you state on page 99 that he will
resign in connection
      with the Corporate Conversion, but state in your response that he will
resign upon the
      completion of the offering. Please revise to reconcile, or advise.
Employment Agreements with new Executive Officers, page 108

4.    We note your new disclosure on page 110 relating to your employment
agreement entered
      into with Dr. Gendreau. We note that the employment agreement for Dr.
Gendreau
      contains provisions relating to potential payments upon a change of
control in addition to
      the severance payment you described. Please revise to discuss such
provisions, as required
      by Item 402(q) of Regulation S-K. In addition, to the extent applicable,
please
      also correspondingly revise your disclosure for the other new employment
agreements
      with new executive officers.
        You may contact Vanessa Robertson at 202-551-3649 or Kevin Vaughn at
202-551-3494
if you have questions regarding comments on the financial statements and
related
matters. Please contact Jason Drory at 202-551-8342 or Dorrie Yale at
202-551-8776 with any
other questions.



                                                            Sincerely,
FirstName LastNameGreg Duncan
                                                            Division of
Corporation Finance
Comapany NameVirios Therapeutics, LLC
                                                            Office of Life
Sciences
September 23, 2020 Page 2
cc:       Darrick M. Mix, Esq.
FirstName LastName