United States securities and exchange commission logo





                            August 20, 2020

       Edward Sitar
       Chief Financial Officer
       9 Meters Biopharma, Inc.
       8480 Honeycutt Road, Suite 120
       Raleigh, North Carolina 27615

                                                        Re: 9 Meters Biopharma,
Inc.
                                                            Form 10-Q for
Fiscal Quarter Ended June 30, 2020
                                                            Filed August 13,
2020
                                                            File No. 001-37797

       Dear Mr. Sitar:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-Q for Fiscal Quarter Ended June 30, 2020

       Financial Statements
       Note 3- Merger and Acquisition, page 18

   1.                                                   We note your disclosure
stating that, on May 6, 2020, you consummated a merger with
                                                        Naia Rare Diseases,
Inc. for consideration of $2.1 million in cash, 4,835,438 shares of
                                                        common stock valued at
$2.2 million, and the pre-payment of certain operating costs on
                                                        behalf of Naia totaling
$0.1 million. Please tell us how you considered furnishing
                                                        financial statements of
Naia Rare Diseases, Inc. and pro forma financial statements in
                                                        accordance with the
guidance in Rule 8-04 of Regulation S-X and Article 11 of
                                                        Regulation S-X,
respectively.
               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.
 Edward Sitar
9 Meters Biopharma, Inc.
August 20, 2020
Page 2

        You may contact Tracie Mariner, Staff Accountant, at (202) 551-3744, or
Terence
O'Brien, Branch Chief, at (202) 551-3355 if you have questions regarding
comments on the
financial statements and related matters.



FirstName LastNameEdward Sitar                           Sincerely,
Comapany Name9 Meters Biopharma, Inc.
                                                         Division of
Corporation Finance
August 20, 2020 Page 2                                   Office of Life
Sciences
FirstName LastName