December 31, 2025

Leslie Marlow
Partner
Blank Rome LLP
1271 Avenue of the Americas
New York, New York 10020

       Re: Anebulo Pharmaceuticals, Inc.
           Schedule TO-I filed December 22, 2025
           Schedule 13E-3 filed December 22, 2025
           SEC File No. 5-92545
Dear Leslie Marlow:

       We have reviewed your filing 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.

Schedule TO-I and Schedule 13E-3 filed December 22, 2025
Purpose and Reasons for the Offer and the Transaction, page 10

1.     State the reasons for the timing of the going private transaction,
taking into account
       that many of the conditions it is intended to address (costs of being a
reporting
       company, lack of liquidity) have existed for some time. See Item 7 of
Schedule 13E-3
       and Item 1013(c) of Regulation M-A.
2.     Explain in further detail the reasons for the transaction structure,
including all of the
       alternative transaction structures considered (besides the reverse stock
split which the
       company abandoned earlier this year). See Item 7 of Schedule 13E-3 and
Item
       1013(b) of Regulation M-A. Your discussion should address the concern
you express
       that the tender offer may not have the desired effect of allowing the
company to
       remain deregistered.
Background of the Transaction, page 12
 December 31, 2025
Page 2

3.     Refer to page 14, third full paragraph. Clarify whether the "certain of
the Company's
       stockholders with significant stock holdings" with whom it discussed
going private
       include Messrs. Lawler and English, who together own 80% of the company.
4.     Where you reference the valuation analyses and materials produced by
Houlihan in
       connection with the fairness analysis it performed in the summer of 2025
in
       connection with the proposed reverse stock split, revise to note how
shareholders can
       access those materials as exhibits to your prior filings.
5.     Refer to page 16 in this section, second to last paragraph. You state
that in July 2025
       after filing a preliminary proxy statement in connection with a
contemplated reverse
       stock split/going private transaction, the company received "inbound
interest from
       potential financial and strategic partners." Expand the Background to
identify the
       parties referenced and explain each contact with such party concerning a
potential
       alternate transaction. Include pricing terms where applicable. In each
case, explain
       why such alternate transaction was not pursued. We note that on page 18,
you refer to
       "the potential buyers with whom the Company had been engaging," but
there is no
       discussion of those contacts and why they ceased, did not result in a
transaction or
       were not pursued.
Reservation of Rights, page 21

6.     Reserving the right to terminate the offer at will in the discretion of
the Board raises
       concerns that this offer is illusory in contravention of Regulation 14E
of the Exchange
       Act. While the company may condition the offer on any number of
objective criteria
       as outlined in the Conditions section of the Offer to Purchase, it may
not reserve the
       right to terminate at will outside those expressed offer conditions.
Please revise.
Conditions of the Offer, page 44

7.     Refer to the fifth bulleted offer condition, which refers to events that
have occurred or
       have been threatened and that may affect the company "or any of our
subsidiaries or
       affiliates." Revise to identify the relevant subsidiaries and affiliates
to which this offer
       condition applies, or consider narrowing its scope.
8.     Refer to the last paragraph of this section on page 46. If an offer
condition is
       "triggered" the bidder must promptly notify target security holders
whether it will
       waive the offer condition or assert it to terminate the offer. Stating
that the bidder may
       waive a condition "at any time and from time to time" or that bidder may
fail to
       exercise its right to assert a condition without being deemed to waive
it is inconsistent
       with bidder's obligation. Please revise.
 December 31, 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 Christina Chalk at 202-551-3263.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Mergers &
Acquisitions