United States securities and exchange commission logo October 1, 2020 Greg Duncan Chief Executive Officer Virios Therapeutics, LLC 44 Milton Avenue Alpharetta, GA 30009 Re: Virios Therapeutics, LLC Amendment No. 2 to Registration Statement on Form S-1 Filed September 25, 2020 File No. 333-248447 Dear Mr. Duncan: We have reviewed your amended registration statement and have the following comment. 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 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 the comment, we may have additional comments. Amendment No. 2 to Registration Statement on Form S-1 Cover Page 1. Your footnotes to the fee table indicate that you are calculating your registration fee based on Rule 457(o). However, based on your revised disclosure that you anticipate your offering price could be up to $11.00 per share, it does not appear you have calculated the registration fee based on the maximum aggregate offer price. Please revise your fee table accordingly. Greg Duncan Virios Therapeutics, LLC October 1, 2020 Page 2 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 October 1, 2020 Page 2 cc: Darrick M. Mix, Esq. FirstName LastName