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                             December 21, 2022

       Jennifer K. Simpson
       Chief Executive Officer
       Panbela Therapeutics, Inc.
       712 Vista Blvd, Suite 305
       Waconia, Minnesota 55387

                                                        Re: Panbela
Therapeutics, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed December 16,
2022
                                                            File No. 333-268854

       Dear Jennifer K. Simpson:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form S-1, filed December 16, 2022

       Cover Page

   1.                                                   On the cover page,
please disclose the date that the best efforts offering will end and any
                                                        arrangements to place
the funds in an escrow, trust, or similar account. If you have not
                                                        made such arrangements,
state this fact and describe the effect on investors. Refer to Item
                                                        501(b)(8)(iii) of
Regulation S-K for guidance.
 Jennifer K. Simpson
FirstName  LastNameJennifer
Panbela Therapeutics, Inc. K. Simpson
Comapany21,
December    NamePanbela
               2022      Therapeutics, Inc.
December
Page 2     21, 2022 Page 2
FirstName LastName
2.       Please revise to clarify, if true, that the "assumed" combined
offering price represents the
         most recent sales price for your common stock, as reported by the
Nasdaq Capital Market,
         and as adjusted to reflect the 1:40 reverse stock split that you
intend to effect prior to the
         offering. With reference to your disclosure in the second paragraph of
page 69, please
         also revise your cover page disclosure to explain how the actual
combined offering price
         will be determined. Refer to Instruction 2 of Item 501(b)(3) of
Regulation S-K for
         guidance. Also, if the combined offering price will be at a discount
to the assumed price,
         then please revise to clarify this point.
        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 Joshua Gorsky at 202-551-7836 or Joe McCann at
202-551-6262 with any
other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Life
Sciences
cc:      Joshua L. Colburn