May 5, 2020
Via EDGAR Transmission
United States Securities and Exchange Commission
Office of Healthcare and Insurance
100 F Street, N.E.
Mail Stop 4720
Washington, D.C. 20549
Attention: Courtney L. Lindsay II
|Re:||Ayala Pharmaceuticals, Inc.|
|Registration Statement on Form S-1|
|Filed March 6, 2020|
|Registration No. 333-236942|
Dear Mr. Lindsay:
In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request the acceleration of the effective date of the above-referenced Registration Statement so that it will become effective on May 7, 2020, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, or at such later time as Ayala Therapeutics, Inc. (the Company) or its counsel may request via telephone call to the staff.
Please contact Keith L. Halverstam of Latham & Watkins LLP, counsel to the Company, at (212) 906-1761, or in his absence, Peter N. Handrinos at (617) 948-6060, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.
|Ayala Pharmaceuticals, Inc.|
|By:||/s/ Roni Mamluk|
|Chief Executive Officer|
|cc:||Keith L. Halverstam, Esq.|
Peter N. Handrinos, Esq.