September 12, 2025

William Elder
CFO and General Counsel
CervoMed Inc.
20 Park Plaza
Suite 424
Boston, MA 02116

       Re: CervoMed Inc.
           Form 10-K for the year ended December 31, 2024
           Filed March 17, 2025
           File No. 001-37942
Dear William Elder:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the year ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Research and Development Expenses, page 84

1.     Please provide proposed revised disclosure to be included in future
filings to disclose
       the costs incurred during each period presented for each of your key
research and
       development projects. If you do not track your research and development
costs by
       project, please disclose that fact, explaining why you do not maintain
and evaluate
       research and development costs by project, and provide other
quantitative disclosure
       that provides more transparency as to the type of research and
development expenses
       incurred (i.e. by nature or type of expense) for any unallocated
expenses which should
       reconcile to total research and development expense on the Statements of
Operations.
       In this regard, quantify the change in each of the factors noted for the
increase in
       research and development expense for each period presented. This would
also apply
       to the factors noted for the increase in your general and administrative
expenses.
 September 12, 2025
Page 2

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

       Please contact Sasha Parikh at 202-551-3627 or Jenn Do at 202-551-3743
if you have
questions regarding comments on the financial statements and related matters.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Life
Sciences