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                             May 4, 2021

       Daniel Schneeberger, M.D.
       Chief Executive Officer
       Anebulo Pharmaceuticals, Inc.
       1415 Ranch Road 620 South, Suite 201
       Lakeway, TX 78734

                                                        Re: Anebulo
Pharmaceuticals, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed April 26,
2021
                                                            File No. 333-254979

       Dear Dr. Schneeberger:

             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 April
15, 2021 letter.

       Amendment No.1 to Registration Statement on Form S-1, Filed April 26,
2021

       Capitalization, page 49

   1.                                                   Please revise your
capitalization table to address the following comments:

                                                              Please update the
number of shares of common stock issued and outstanding actual,
                                                            pro forma and pro
forma, as adjusted in the table to give effect of the forward stock
                                                            split, as well as
the conversion of your series A preferred stock and the exercise of
                                                            your milestone
warrants, so investors have a complete picture of your outstanding
                                                            shares and their
impact.
                                                              Please include
the conversion of your series A preferred stock and the exercise of
                                                            your milestone
warrants as part of your pro forma balances, to give effect of your
 Daniel Schneeberger, M.D.
Anebulo Pharmaceuticals, Inc.
May 4, 2021
Page 2
          existing shareholders, such that the pro forma, as adjusted, would
reflect the new
          shareholder proceeds upon the closing of this offering.
Financial Statements
Note 12d. Subsequent Events, page F-15

2.    You state on pages F-15 and F-26 that the Company approved a 6-for-1
forward stock
      split contingent upon the successful completion of the Company's IPO,
whereas on pages
      9, 12 and 92 you state that the forward stock split will occur prior to
the effectiveness of
      your offering. Please revise throughout the filing for consistency. In
addition, if the
      forward split will occur prior to or upon effectiveness, please revise
your annual and
      interim financial statements and financial data throughout the filing to
give retroactive
      effect of the forward stock split in accordance with ASC 505-10-S99-4.

       You may contact Li Xiao at 202-551-4391 or Mary Mast at 202-551-3613 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Margaret Schwartz at 202-551-7153 or Jeffrey Gabor at 202-551-2544 with any
other questions.



                                                            Sincerely,
FirstName LastNameDaniel Schneeberger, M.D.
                                                            Division of
Corporation Finance
Comapany NameAnebulo Pharmaceuticals, Inc.
                                                            Office of Life
Sciences
May 4, 2021 Page 2
cc:       Spencer G. Feldman, Esq.
FirstName LastName