November 4, 2024

Stephen Yoder
Chief Executive Officer
Pieris Pharmaceuticals, Inc.
225 Franklin Street, 26th Floor
Boston, MA 02110

        Re: Pieris Pharmaceuticals, Inc.
            Amendment No. 3 to Registration Statement on Form S-4
            Filed October 29, 2024
            File No. 333-281459
Dear Stephen Yoder:

     We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our October 25,
2024 letter.

Amendment No. 3 to Registration Statement on Form S-4
Palvella Therapeutics, Inc., page 11

1.     We acknowledge your response to prior comment 1, which we reissue. We
continue
       to believe that the failure of QTORIN-rapamycin to meet primary clinical
trial
       endpoints in two prior trials targeting Gorlin Syndrome and pachyonychia
congenita
       may be considered material information and should be disclosed in the
Summary and
       Palvella's Business section. In this regard, we note: (1) Palvella's
current and past
       product candidates utilize or utilized QTORIN, Palvella's proprietary
anhydrous
       topical gel platform, as a mechanism to deliver rapamycin for the
treatment of various
       targeted diseases; and (2) your disclosure on page 70 that "a failure in
any one
       QTORIN-based program may decrease trust in its technology and affect its
ability to
       conduct clinical programs for other QTORIN-based product candidates."
Please either
 November 4, 2024
Page 2

       revise your disclosure as previously requested or provide an analysis
supporting your
       determination that the information is not material in your response
letter.
        Please contact Gary Newberry at 202-551-3761 or Vanessa Robertson at
202-551-
3649 if you have questions regarding comments on the financial statements and
related
matters. Please contact Lauren Sprague Hamill at 303-844-1008 or Laura Crotty
at 202-551-
7614 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Joseph Walsh