One Financial Center Boston, MA  02111 617 542 6000

September 23, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E. Washington, D.C. 20549

Attention: Sasha Parikh and Jenn Do

Ladies and Gentlemen:

We are submitting this letter on behalf of our client, CervoMed Inc., a Delaware corporation (the “Company”), in response to the written comments from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) received by your letter dated September 12, 2025 (the “Comment Letter”), relating to the above-referenced Annual Report on Form 10-K.

For reference, we have set forth below in italics the Staff’s comment from the Comment Letter and have keyed the Company’s responses to the numbering of the comment and the headings used in the Comment Letter.

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

BOSTON    LOS ANGELES    MIAMI    NEW YORK    SAN DIEGO    SAN FRANCISCO    TORONTO    WASHINGTON

MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

MINTZ   September 23, 2025 Page 2

The Company respectfully acknowledges the Staff’s comment and, in future filings, will expand its disclosure in accordance with the Staff’s comment.

By way of example, using information regarding the Company’s research and development expenses and general and administrative expenses for the six months ended June 30, 2025 and 2024, the Company expects future disclosure to read substantially as follows:

Research and Development Expenses

Although neflamapimod is our only drug candidate in active development and research and development expenses are reported as a single segment, we track certain outsourced development, outsourced personnel costs and other external research and development costs of our neflamapimod clinical and non-clinical development programs on an indication-by-indication basis. A portion of our external costs are related to neflamapimod’s development generally and therefore not allocated on such a basis and, similarly, we do not track internal research and development costs by indication.

The following table summarizes our research and development expenses for the six months ended June 30, 2025 and 2024.

The aggregate $3.4 million increase in research and development expenses was primarily due to an increase of $1.7 million in personnel costs, driven by higher headcount and outsourced consulting costs, and increases of $1.0 million and $0.7 million in other clinical and non-clinical costs and other research and development costs, respectively, driven by increased non-clinical and CMC activities to evaluate, analyze and address the drug product issue identified in December 2024. These increases were offset by a net decrease in costs related to our neflamapimod clinical programs, as a $1.3 million decrease in costs related to our DLB program – where the final patient visit of the Extension Phase of our RewinD-LB Trial was completed during the quarter – was partially offset by an aggregate increase of $1.1 million in costs related to our recovery after stroke and PPA programs, as our Restore Trial and Phase 2a trial in the nonfluent/agrammatic variant of PPA were both initiated in the second quarter of 2025.

MINTZ   September 23, 2025 Page 3

General and Administrative Expenses

The following table summarizes our general and administrative expenses for the six months ended June 30, 2025 and 2024.

The aggregate $1.0 million increase in general and administrative expenses was primarily due to an increase of $0.7 million in personnel costs (inclusive of stock-based compensation), driven by higher headcount and severance costs related to the separation of our Former COO, plus an increase of $0.3 million in professional fees, insurance, taxes, and other miscellaneous general and administrative expenses.

* * * * *

If the Staff should have any further questions, or would like further information, concerning the responses above, please do not hesitate to contact me at (617) 348-4416 or jsmccaffrey@mintz.com. We thank you for your time and attention.