VivoSim Labs, Inc.
11555 Sorrento Valley Road, Suite 100
San Diego, CA 92121
March 31, 2026
VIA EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-0406
Attention: Tim Buchmiller
| Re: | VivoSim Labs, Inc. |
Registration Statement on Form S-1, as amended
Initially Filed on March 27, 2026
Registration No. 333-294716
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, VivoSim Labs, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-1 (Registration No. 333-294716) of the Company, filed with the Securities and Exchange Commission on March 27, 2026 and amended on March 31, 2026 (the “Registration Statement”), be accelerated so that the Registration Statement shall become effective at 4:00 p.m. (Eastern Time) on March 31, 2026, or as soon as possible thereafter.
The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement.
It would be appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Samantha Eldredge of Paul Hastings LLP, by telephone at (650) 320-1838 or by email at samanthaeldredge@paulhastings.com. The Company hereby authorizes Ms. Eldredge to orally modify or withdraw this request for acceleration.
| Sincerely, | |||
| VIVOSIM LABS, INC. | |||
| By: | /s/ Keith Murphy | ||
| Name: | Keith Murphy | ||
| Title: | Executive Chairman | ||
| cc: | Samantha H. Eldredge, Esq. (Paul Hastings LLP) |