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                            July 21, 2022

       Jorge Santos da Silva
       Founder & Chief Executive Officer
       MoonLake Immunotherapeutics
       Dorfstrasse 29
       6300 Zug
       Switzerland

                                                        Re: MoonLake
Immunotherapeutics
                                                            Amendment No. 4 to
Registration Statement on Form S-1
                                                            Filed July 15, 2022
                                                            File No. 333-262643

       Dear Dr. Santos da Silva:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
16, 2022 letter.

       Amendment No. 4 to Registration Statement on Form S-1

       Cover Page

   1.                                                   We note your response
to prior comment 1 and your revised disclosure on the cover page.
                                                        We reissue our comment
in full. Please revise your cover page to disclose the price that
                                                        each of the Selling
Shareholders paid for the Class A Ordinary Shares.
       Risk Factors
       Future resales, or the perception of future resales, of Class A Ordinary
Shares, including the
       Registrable Shares offered for resale..., page 35

   2.                                                   We note your response
to prior comment 4 and your revised disclosure on page 35
 Jorge Santos da Silva
MoonLake Immunotherapeutics
July 21, 2022
Page 2
      regarding the total number of Class A Ordinary Shares that are being
offered as well as
      the fact that the total number of shares being offered in this
transaction represent 92.38%
      of the total outstanding Class A Ordinary Shares and outstanding Class C
Ordinary Shares
      on an as-converted, fully diluted basis. We reissue our comment in part.
Please revise
      your disclosure to note the purchase price of the shares being registered
for resale.
      Additionally, to the extent applicable, please disclose that even though
the current trading
      price is significantly below the SPAC IPO price, the private investors
have an incentive to
      sell their shares because they will still profit on such sales due to the
fact that they
      purchased their shares at a lower price than public investors.
General

3.    We note your response to prior comment 7 and your revised disclosure
throughout the
      registration statement noting that the Selling Shareholders "may earn a
positive rate of
      return by selling" their Class A Ordinary Shares. We reissue our comment
in full. Please
      revise to disclose the price that each Selling Shareholder paid for the
shares being
      registered for resale. Highlight any differences in the current trading
price, the prices at
      which each of the Selling Shareholders acquired their shares, and the
price at which the
      public shareholders acquired their shares. Disclose that the public
shareholders may not
      experience a similar rate of return on the securities as the Selling
Shareholders due to
      differences in the purchase prices and the current trading price. Please
also disclose the
      potential profit the Selling Shareholders will earn based on the current
trading price, if
      any. Lastly, please include appropriate risk factor disclosure on these
points.
       You may contact Joshua Gorsky at 202-551-7836 or Laura Crotty at
202-551-7614 with
any questions.



                                                            Sincerely,
FirstName LastNameJorge Santos da Silva
                                                            Division of
Corporation Finance
Comapany NameMoonLake Immunotherapeutics
                                                            Office of Life
Sciences
July 21, 2022 Page 2
cc:       Branden Berns
FirstName LastName