United States securities and exchange commission logo October 19, 2022 Manu Ohri Chief Financial Officer GT Biopharma, Inc. 8000 Marina Blvd., Suite 100 Brisbane, CA 94005 Re: GT Biopharma, Inc. Registration Statement on Form S-3 Filed October 13, 2022 File No. 333-267870 Dear Manu Ohri: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Jimmy McNamara at 202-551-7349 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Roger Bivans