United States securities and exchange commission logo

                          January 6, 2022

       Michael Grey
       Interim Chief Executive Officer
       Spruce Biosciences, Inc.
       2001 Junipero Serra Boulevard, Suite 640
       Daly City, California 94014

                                                        Re: Spruce Biosciences,
Statement on Form S-3
                                                            Filed December 30,
                                                            File No. 333-261960

       Dear Mr. Grey:

              This is to advise you that we have not reviewed and will not
review your registration

               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 Chris
Edwards at 202-551-6761 with any questions.


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Daniel P. Eitutis