December 16, 2024

Kaitlyn Arsenault
Chief Financial Officer
Skye Bioscience, Inc.
11250 El Camino Real, Suite 100
San Diego, CA 92130

       Re: Skye Bioscience, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 10-Q for the Quarterly Period Ended September 30, 2024
           File No. 000-55136
Dear Kaitlyn Arsenault:

       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 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-Q for the Quarterly Period Ended September 30, 2024
9. Contingencies, page 18

1.     Please tell us and quantify the methods and key assumptions underlying
the change in
       estimate for legal contingencies of $4,553,468 that reduced the
liability for accrued
       legal contingencies to $1,792,337 as of September 30, 2024. In
particular, explain
       how the Ninth Circuit court's decision vacating the Cunning Lawsuit
judgment and
       remanding this case back to the District Court supported your release of
this litigation
       loss provision. Refer us to the technical guidance upon which you relied
and revise
       your disclosure accordingly.


        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.
 December 16, 2024
Page 2



       Please contact Frank Wyman at 202-551-3660 or Bonnie Baynes at
202-551-4924
with any questions.



                                                      Sincerely,

                                                      Division of Corporation
Finance
                                                      Office of Life Sciences