March 30, 2020

Steven Lo
President and Chief Executive Officer
Zosano Pharma Corp
34790 Ardentech Court
Fremont, CA 94555

       Re: Zosano Pharma Corp
           Registration Statement on Form S-3
           Filed March 16, 2020
           File No. 333-237187

Dear Mr. Lo:

       We have limited our review of your registration statement to those
issues we have
addressed in our comment.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comment applies to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to the comment, we may have additional comments.

Registration Statement on Form S-3

Cover Page

1.     It appears you may be relying on General Instruction I.B.6 of Form S-3
to register the
       primary offering of securities covered by the registration statement. As
such, please revise
       to disclose the aggregate market value of your outstanding voting and
non-voting common
       equity, as well as the amount of all securities offered pursuant to
General Instruction I.B.6
       of Form S-3 during the previous 12 months up to and including the date
of your
       prospectus. We refer you to Instruction 7 to General Instruction I.B.6.
        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.
 Steven Lo
Zosano Pharma Corp
March 30, 2020
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Chris Edwards at (202) 551-6761 or Joe McCann at (202)
551-6262 with
any questions.



                                                           Sincerely,
FirstName LastNameSteven Lo
                                                           Division of
Corporation Finance
Comapany NameZosano Pharma Corp
                                                           Office of Life
Sciences
March 30, 2020 Page 2
cc:       Kathleen M. Wells
FirstName LastName