March 11, 2025 Michael Breen Executive Chairman of the Board and Interim Chief Executive Officer GT Biopharma, Inc. 505 Montgomery Street 10th Floor San Francisco, CA 94111 Re: GT Biopharma, Inc. Registration Statement on Form S-3 Filed March 6, 2025 File No. 333-285618 Dear Michael Breen: 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 Daniel Crawford at 202-551-7767 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Louis A. Wharton, Esq.