June 10, 2025

Melissa Tosca
Chief Financial Officer
Kiora Pharmaceuticals, Inc.
332 Encinitas Blvd., Suite 102
Encinitas, CA 92024

       Re: Kiora Pharmaceuticals, Inc.
           Form 10-K for the fiscal year ended December 31, 2024
           Filed March 25, 2025
           File No. 001-36672
Dear Melissa Tosca:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       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 fiscal year ended December 31, 2024
December 31, 2024 Financial Statements
7. Intangible Assets and In-Process R&D, page F-24

1.     In your future filings, please revise the rollforward on page F-24 to
present the
       amount of impairment charges for in-process research and development
such as the
       $2.0 million impairment recorded during 2024.
12. Commitments and Contingencies, page F-33

2.     Regarding the license agreement with TOI, you state on page F-34 that
you recorded
       offsetting expense credits of $2.9 million related to reimbursable
KIO-301 expenses.
       However, we note from the fourth quarter of 2024 earnings release that
you received
       $3.3 million in such reimbursable expenses. For the first quarter of
2025, it appears
       you received $1.8 million in these expenses but the amount you have
recorded for the
       three months ended is $2.0 million. Please address the following in your
response and
       provide revisions in future filings as deemed applicable:
 June 10, 2025
Page 2

             We note from pages 7, 9 and 29 the disclosure that TOI is
responsible for all
           research and development costs of KIO 301. If so, please separately
quantify such
           as the foregoing R&D expenses that were reimbursed to you.
             Tell us the amounts you have been reimbursed or received compared
to what you
           have incurred for the recent periods. To the extent such amounts are
material,
           provide a tabular presentation of such amounts in future filings, to
be
           accompanied by a description of your accounting for such amounts.
             Please describe the purpose and/or nature of the liability account
Accrued
           Collaboration Credit and provide a rollforward thereof, identifying
the
           transactions that increase or decrease this balance.

        In closing, 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 Jenn Do at 202-551-3743 or Kevin Vaughn at 202-551-3494
with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences