September 9, 2025

Ben Hwang
Chief Executive Officer
Profusa, Inc.
626 Bancroft Way, Suite A
Berkeley, CA 94710

       Re: Profusa, Inc.
           Registration Statement on Form S-1
           Filed August 29, 2025
           File No. 333-289958
Dear Ben Hwang:

       We have conducted a limited review of your registration statement and
have the
following comment.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a 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 this letter, we may have additional comments.

Registration Statement on Form S-1
General

1.     We note your disclosure throughout the registration statement regarding
your
       purchase of bitcoin, including your risk factor disclosures starting on
page 54, your
       disclosures on page 80 that you intend to use the proceeds from your
committed
       equity facility with Ascent entered into on July 28, 2025 for up to
$100,000,000 of
       shares of your common stock "exclusively for the purchase of Bitcoin,"
and your
       statement on F-54 that "[as] of these June 30, 2025 financial
statements, [you
       have] purchased $1.0 million of Bitcoin as part of [your] ongoing
treasury strategy".
       Please disclose your current bitcoin and/or cryptocurrency holdings as
of the date of
       the registration statement.
 September 9, 2025
Page 2

        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.

       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 Juan Grana at 202-551-6034 or Jane Park at 202-551-7439
with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Marc Rivera, Esq.