September 22, 2025

Richard Anthony Cunningham
Chief Executive Officer
Anebulo Pharmaceuticals, Inc.
1017 Ranch Road 620 South, Suite 107
Lakeway, Texas 78734

       Re: Anebulo Pharmaceuticals, Inc.
           Schedule 13E-3/A filed September 15, 2025
           File No. 005-92545
           _
           Revised Preliminary Proxy Statement filed September 15, 2025
           File No. 001-40388
Dear Richard Anthony Cunningham:

       We have reviewed your filings 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 these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

       After reviewing your response to these comments, we may have additional
comments.

Revised Preliminary Proxy Statement on Schedule 14A filed September 15, 2025
General

1.     We note that your response to prior comment 1 in our letter dated August
14, 2025
       indicates that Mr. English, 22NW Fund, LP, and Dr. Lawler signed support
       agreements wherein they "indicated that [they] will vote in favor of the
Reverse Stock
       Split Proposal at the Special Meeting." Please provide the disclosure
required under
       Item 1005(e) of Regulation M-A and Item 5 of Schedule 13E-3 and file
such
       agreements as exhibits pursuant to Item 1016(e) of Regulation M-A and
Item 16 of
       Schedule 13E-3.
2.     We note your response to prior comment 1 and are unable to agree that
Mr. English,
       22NW Fund, LP, and Dr. Lawler are not affiliates engaged in a Rule 13e-3
       transaction. In addition to the factors noted in prior comment 1, we
note your
 September 22, 2025
Page 2

       disclosure on page 23 indicating that the Special Committee was formed
in response
       to interest expressed by certain Board members in a going private
transaction and that,
       as indicated in your response, these affiliates signed support
agreements in favor of
       the transaction. Please revise the Schedule 13E-3 to include Mr.
English, 22NW Fund,
       LP, and Dr. Lawler as filing persons and provide all of the disclosure
required for
       each as a filing person as a result of this comment.
Background of the Transaction, page 21

3.     We note your response to prior comment 4 and the revised disclosure
indicating that
       Houlihan Capital provided two fairness opinions, one dated July 11,
2025, reflecting a
       fixed stock split ratio, and another dated July 15, 2025, reflecting a
stock split
       ratio range. Please ensure your disclosure separately summarizes both
opinions and
       explains the changes between the July 11 opinion and the July 15
opinion, as required
       under Item 1015 of Regulation M-A and Item 9 of Schedule Schedule 13E-3,
and file
       the July 11, 2025, opinion as required under Item 1016(c) of Regulation
M-A and
       Item 16 of Schedule 13E-3.
4.     We note your response to prior comment 5. Please also provide the
disclosure
       required under Item 1015(a) of Regulation M-A and file as an exhibit the
July 10,
       2025, draft report and summarize any material changes or updates between
the draft
       and final reports.
Fairness of the Transaction, page 31

5.     Please revise what appears to be an errant partial sentence at the
bottom of page 31.
6.     We note your response to prior comment 7 and reissue the comment. Item
1014 of
       Regulation M-A requires a determination of fairness of a transaction
specifically to
       unaffiliated security holders. Particularly because, as indicated in
your other
       responses, a majority of the Company's outstanding shares are
contractually obligated
       to be voted in favor of the Transaction, the stockholder vote does not
appear to
       evidence procedural fairness to unaffiliated stockholders. Please revise
to avoid the
       implication that the stockholder vote provides procedural fairness to
unaffiliated
       stockholders.
7.     We note your response to prior comment 9 and the added disclosure that
the Special
       Committee and the Board did not view the fact that both the Company and
the Special
       Committee relied on Blank Rome as a "lack of independent legal counsel."
While you
       may explain why you believe it did not negatively impact procedural
fairness, please
       revise to remove the implication that the Board and the Special
Committee had
       independent legal counsel while both were receiving advice from the same
source.
 September 22, 2025
Page 3

        We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

       Please direct any questions to Laura McKenzie at 202-551-4568.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Mergers &
Acquisitions