March 21, 2025

Stephan Jackman
Chief Executive Officer
Alzamend Neuro, Inc.
3480 Peachtree Road NE
Second Floor, Suite 103
Atlanta, GA 30326

       Re: Alzamend Neuro, Inc.
           Registration Statement on Form S-3
           Filed March 13, 2025
           File No. 333-285788
Dear Stephan Jackman:

       We have conducted a limited review of your 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 our 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.

Registration Statement on Form S-3
General

1.     We note that the registration statement includes the proposed resale of
common shares
       underlying preferred shares and that the preferred shares are to be
issued pursuant to
       an equity line financing arrangement. Question 139.13 of the Securities
Act Sections
       Compliance and Disclosure Interpretations, available on our website,
provides that, in
       order for shares to be registered on a resale basis under an equity line
financing, the
       resale registration statement must be on a form that the company is
eligible to use for
       a primary offering. Given that the aggregate market value of your common
equity
       held by non-affiliates does not exceed the $75 million threshold set
forth in General
       Instruction I.B.1 to Form S-3, it does not appear that you are eligible
to use Form S-3
       for a primary offering. Accordingly, please provide us with an analysis
supporting
 March 21, 2025
Page 2

       your determination that the offering may be registered on Form S-3 or
amend your
       registration statement as appropriate.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Jessica Dickerson at 202-551-8013 or Joshua Gorsky at
202-551-7836
with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Life
Sciences
cc:   Kenneth A. Schlesinger, Esq.