September 9, 2024

 

VIA EDGAR

 

Division of Corporation Finance

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention: Messrs. Dillon Hagius and Tim Buchmiller

 

Re:

Kairos Pharma, Ltd.

Registration Statement on Form S-1
File No. 333-274805

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and the other underwriters, hereby join in the request of Kairos Pharma, Ltd. that the effective date of the above-referenced registration statement be accelerated so as to permit it to become effective at 5:00 p.m., Eastern time, on Wednesday, September 11, 2024, or as soon thereafter as practicable.

 

Pursuant to 460 under the Act, we wish to advise you that the underwriters have distributed as many copies of the preliminary prospectus dated August 16, 2024 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such preliminary prospectus.

 

The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 

  Very truly yours,
   
  Boustead Securities, LLC
  As representative of the underwriters
   
  By: /s/ Lincoln Smith
  Name: Lincoln Smith
  Title: Chief Executive Officer