United States securities and exchange commission logo

                             January 4, 2021

       Berndt Modig
       Chief Executive Officer
       Pharvaris, B.V.
       J.H. Oortweg 21
       2333 CH Leiden, The Netherlands

                                                        Re: Pharvaris, B.V.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted December
18, 2020
                                                            CIK No. 0001830487

       Dear Mr. Modig:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 1 to Draft Registration Statement on Form F-1 submitted
December 18, 2020

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your revised
disclosure in response to prior comment 2. You continue to describe
                                                        your potential product
candidates as "potent," a "potent inhibitor," "potent antagonist" or
                                                        "a potent and selective
treatment for acute" HAE" on pages 1, 3, 94, 95 and
                                                        elsewhere. Your
disclosure continues to inappropriately indicate your conclusions
                                                        regarding the efficacy
of your product candidate by stating that your product candidate
                                                        was observed to be
potent. Please delete such references here and throughout your
                                                        registration statement.
 Berndt Modig
Pharvaris, B.V.
January 4, 2021
Page 2
2.       We note your response to our prior comments 3, 15 and 17. Despite your
         disclosure, we continue to believe that it is not appropriate for you
to compare PHA121
         with icatibant where the trials were not head-to-head. In addition,
statements that your
         early-stage product candidate is "more potent" than an FDA approved
drug, such as your
         statement, "[PHA121 is] more potent inhibitor than icatibant" and
"PHA121 was shown to
         be consistently 25-fold more potent at inhibiting the effects of
administered bradykinin
         than icatibant on a molar basis," are inappropriate. Please revise
your disclosure
         throughout your prospectus accordingly to remove such comparisons. You
can discuss
         your Bradykinin Challenge Study as well as the fact that you believe
it establishes a proof
         of concept; however, you should not make comparison statements that
imply that your
         product candidate is more effective or more potent than an approved
product candidate
         unless the results were derived from a head-to-head study.
Pipeline, page 4

3.       We note your response to our prior comment 7 and disagree with your
reasons for
         continuing to show that you have completed Phase 1 for PHVS416 in your
pipeline table
         given your disclosure elsewhere that you have ongoing Phase 1 studies.
The table should
         depict your material product candidates and their current stage of
development. You may
         include a narrative discussion regarding the fact that you anticipate
beginning a Phase 2
         study prior to the completion of your ongoing Phase 1 studies.
Business, page 88

4.       We note your MD&A disclosure that "[i]n 2019, a milestone payment of
 300,000 was
         paid to a third-party upon commencement of Phase 1 development." In
your Business
         section please disclose the material terms of your material
agreements, such as the name
         of the third party, potential aggregate milestone payments, expiration
term and termination
         provisions related to this agreement. In addition, please file the
agreement as an exhibit or
         tell us why you believe such agreement is not required to be filed.
See Item 601(b)(10) of
         Regulation S-K.
FirstName page 100
          LastNameBerndt Modig
5.         NamePharvaris,
       We note  your revisedB.V.
                              graphic on page 101 as well as the inclusion of a
legend. However,
Januaryplease include
        4, 2021  Page narrative
                      2         disclosure to explain the graphic on page 101.
FirstName LastName
 Berndt Modig
FirstName  LastNameBerndt Modig
Pharvaris, B.V.
January    NamePharvaris, B.V.
        4, 2021
Page 3 4, 2021 Page 3
FirstName LastName
       You may contact Julie Sherman at 202-551-3640 or Kate Tillan at
202-551-3604 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jason L. Drory at 202-551-8342 or Chris Edwards at 202-551-6761 with
any other


                                                         Division of
Corporation Finance
                                                         Office of Life
cc:      Sophia Hudson, Esq.