United States securities and exchange commission logo

                               December 9, 2020

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

                                                        Re: Pharvaris, B.V.
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted November
12, 2020
                                                            CIK No. 0001830487

       Dear Mr. Modig:

              We have reviewed your 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

       Draft Registration Statement on Form F-1 submitted November 12, 2020

       Market and Industry Data, page ii

   1.                                                   Your statement that you
have not independently verified third-party market and industry
                                                        information may imply
an inappropriate disclaimer of responsibility with respect to the
                                                        third party
information. Please either delete the statement or specifically state that you
                                                        liable for such
       Prospectus Summary
       Overview, page 1

   2.                                                   Here and elsewhere
throughout your prospectus you refer to your product candidate,
                                                        PHA121, as being
"highly potent," "a potent antagonist" and a "potent and selective
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         treatment for acute HAE." Given the stage of your product development,
it appears
         premature to describe your product candidates as potent, which implies
they are effective.
         Similarly, we note your reference to your product candidates'
"anticipated therapeutic
         profile." Please revise your disclosure to remove such statements
throughout your
3.       We refer to the comparisons here and elsewhere in your prospectus
where you state
         that: "PHA121 was shown to be consistently 25-fold more potent than
icatibant on a molar
         basis," "more potent than icatibant," "observed greater potency for
PHA121 compared to
         icatibant," and "observed that PHA121 was more potent in blocking the
effects of BK in
         humans than icatibant, when comparing the PHA121 results of the trial
to published data
         on icatibant." Please remove these comparisons as they do not appear
to be based on
         a head-to-head studies or tell us why you believe such comparisons are
4.       We note your disclosure in this section and in the Business section
that you plan to initiate
         a "pivotal" trial in the on-demand setting following your planned
RAPIDe-1 trial. Please
         revise the disclosure in these sections to make it clear that even if
you receive positive
         data from RAPIDe-1 trial, the U.S. Food and Drug Administration (FDA)
or other
         regulators may require you to conduct additional trials.
5.       Please place your discussion of the bradykinin challenge in
appropriate context with
         reference to your limited trial data to date and indicate that you
have not yet conducted a
         Phase 2 study. Additionally, we note your disclosure on page 3 that
you expect your
         planned trials of PHVS416 and PHVS719 will support a regulatory
application for
         PHVS719 in prophylaxis for HAE. Please remove this disclosure as it is
premature and
         speculative given the current stage of development.
Differentiation of PHA121, page 3

6.       We note your statements here and throughout your document that your
product candidates
         are designed or have the potential to be "best-in-class." This term
suggests that the product
         candidate is effective and likely to be approved. Please delete these
references throughout
         your registration statement. If your use of this term was intended to
convey your belief
         that the product is based on a novel technology or approach and/or is
further along in the
         development process, you may discuss how your technology differs from
technology used
         by competitors and, if applicable, that you are not aware of competing
products that are
         further along in the development process. Statements such as these
should be
         accompanied by cautionary language that the statements are not
intended to give any
         indication that the product candidate has been proven effective or
that it will receive
         regulatory approval.
Our Pipeline, page 4

7.       Please revise the pipeline table on page 4, which also appears on page
91, so that it
         reflects the current status of your product candidates. For example,
we note your
         disclosure on page 97 that you still have ongoing and planned Phase 1
studies for your
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         product candidate, such that it does not appear that you have
completed your Phase 1
         studies. In addition, we note your disclosure on page 103 that you
plan to conduct a Phase
         1 bridging study in 2021 for PHVS719 and that you only have a
"prototype formulation
         for extended release." Accordingly, please remove the dashed box from
your pipeline
         chart for PHVS719.
Recent Developments
COVID-19, page 6

8.       We note your disclosure that the COVID-19 pandemic caused you to
experience a delay
         in enrollment in your Phase 1 study of PHA121. Please revise to
discuss in greater detail
         the extent of the delay and also disclose if any of your other
clinical trials have been
         affected. Please also revise any associated risk factors to
specifically discuss the impact
         COVID-19 has actually had on your clinical trials to date given the
amount of time that
         has passed since the initial outbreak.
Implications of Being an    Emerging Growth Company    and a Foreign Private
Issuer, page 9

9.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
Risk Factors, page 14

10.      Please update your risk factor disclosure by relocating risks that
could apply generally to
         any company or offering of securities to the end of the risk factor
section under the
         caption    General Risk Factors.    Refer to Item 105 of Regulation
S-K and
         SEC Release Nos. 33-10825; 34-89670.
Use of Proceeds, page 67

11.      We note your disclosure that you intend to use a portion of the net
proceeds to fund the
         clinical development of PHVS416 and PHVS719. Please revise to specify
how far in the
         clinical development of the associated product candidates you expect
to reach with the net
         proceeds. In this regard, we note that you have a number of clinical
trials planned for the
         associated product candidates. Also, to the extent material amounts of
other funds are
         necessary to accomplish your specified purposes, state the amounts of
such other funds
         and the sources thereof.
Management's Discussion and Analysis of Financial Condition and Results of
Critical Accounting Estimates and Judgments
Share-Based Payments, page 85

12.      Once you have an estimated offering price or range, please explain to
us how you
         determined the fair value of the common stock underlying your equity
issuances and the
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Pharvaris, B.V.
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              2020        B.V.
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         reasons for any differences between the recent valuations of your
common stock leading
         up to the IPO and the estimated offering price. This information will
help facilitate our
         review of your accounting for equity issuances including stock
compensation and
         beneficial conversion features.
Current Treatments and Their Limitations, page 94

13.      We note your disclosure that "four other angioedema-specific oral
medications for acute,
         as well as prophylactic, use are in clinical development." Please
provide additional
         disclosure about these potential competitors, including the stage of
Overview, page 95

14.      We note your statement here that "PHA121 showed efficacy and clear
         activity." You also state on page 97 that, "PHA121 was safe and well
tolerated when
         administered orally up to single doses of 22 mg." Please revise these
and all similar
         statements throughout your prospectus that state or imply that your
product candidates are
         safe or effective as these determinations are solely within the
authority of the FDA and
         comparable regulatory bodies.
15.      We note your disclosure that "PHA121 demonstrated longer duration and
faster onset of
         activity than injected icatibant in the same study." Please expand
your disclosure to
         describe the icatibant study, including who completed the study, how
the 0.6 mg/kg dose
         of icatibant compares to the doses depicted in PHA121, and discuss the
vehicle in the
         icatibant study. To the extent the icatibant study is not a
head-to-head study please remove
         this disclosure or tell us why you believe your comparison is
16.      The graphic provided on the bottom of page 95 contains text that is
illegible. Please revise
         this figure accordingly. In addition, the graphic contains
abbreviations such as "HMWK"
         that are not defined. Please define abbreviations in all graphics here
         elsewhere. Additionally, all graphics throughout the prospectus should
be accompanied
         by narrative disclosure that clearly explains the context for the
Bradykinin Challenge Study, page 98

17.      We note your comparison of the results of PHA121 observed in your
         Challenge Study to published reports of clinical trial data for
icatibant as well as your
         related predictions on page 2. As these comparisons are not based on
head-to-head studies,
         please tell us why you believe it is appropriate to include them.
Address in your response
         whether you expect to be able to rely on such comparisons to support
an application for
         marketing approval.
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PHA121-C002 (SAD extension), page 100

18.      We note your disclosure regarding the occurrence of treatment-related
adverse events
         related to PHA121. Please expand your disclosure to provide the number
of patients who
         experienced each such treatment-related adverse event.
Intellectual Property, page 104

19.      Please expand your disclosure to clarify the patent term for your sole
granted U.S. patent
         for PHA121. In addition, please identify the material jurisdictions
that are included in
         your "27 pending non-U.S. applications."
Corporate Structure, page 127

20.      In order to provide appropriate context for your disclosure, please
revise to include an
         organizational chart that identifies the significant subsidiaries of
the Company. Refer
         to Item 4(a) of Form F-1 and Item 4.C of Form 20-F.
Employees, page 127

21.      Please provide a breakdown of each main category of activity and
geographic location for
         each of your employees. Refer to Item 4(a) of Form F-1 and Item 6.D of
Form 20-F.
Related Party Transactions, page 140

22.      We note your disclosure that you issued shares of Series C preferred
stock in November
         2020. Please identify the related parties and describe the related
party interest.
Financial Statements
Note 21. Events After the Reporting Period, page F-26

23.      We see from your disclosure herein that you granted 600,000 share
options on January 1,
         2020. Please reconcile this disclosure with that on page II-2 that
indicates that 600,000
         share options were granted on December 13, 2019.

24.      At first use, please define abbreviations. For example only, we note
that "DDI," "SAD"
         and "GLP" on page 97 and "DBP" on page 99 are not defined at first
 Berndt Modig
Pharvaris, B.V.
December 9, 2020
Page 6

       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 Christine Westbrook at 202-551-5019
with any other

FirstName LastNameBerndt Modig
                                                         Division of
Corporation Finance
Comapany NamePharvaris, B.V.
                                                         Office of Life
December 9, 2020 Page 6
cc:       Sophia Hudson, Esq.
FirstName LastName