September 4, 2025

Maria Maccecchini
President, Chief Executive Officer and Acting Chief Financial Officer
Annovis Bio, Inc.
101 Lindenwood Drive, Suite 225
Malvern, PA 19355

       Re: Annovis Bio, Inc.
           Form 10-K for the fiscal year ended December 31, 2024
           Filed March 21, 2025
           File No. 001-39202
Dear Maria Maccecchini:

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

       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
our 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
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 83

1.     We note your statement on page 82 that you "track and record information
regarding
       external research and development expenses for each study or trial that
we conduct."
       However, you have not provided such a breakout on page 83, nor have you
       quantified, in the accompanying explanation, the changes in the several
factors
       identified as having contributed to the consolidated change. Given
research and
       development (R&D) expenses continue to account for most of your
operating
       expenses and that buntanetap is now being studied in two Phase 3 trials
for multiple
       indications, please provide revised disclosure to be included in future
filings,
       beginning with your Form 10-Q for the period ended September 30, 2025,
to quantify
       your external R&D expenses by program and indication for each period
presented. As
       part of your response, please provide what this disclosure would have
looked like had
       it been included in your December 31, 2024 Form 10-K, March 31, 2025
Form 10-Q
 September 4, 2025
Page 2

       and June 30, 2025 Form 10-Q.
        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 Vanessa Robertson at
202-551-3649 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences