United States securities and exchange commission logo





                             May 23, 2022

       Vlad Vitoc, M.D., M.B.A.
       Chief Executive Officer
       MAIA Biotechnology, Inc.
       4444 West Lake Street, Suite 1700
       Chicago, IL 60606

                                                        Re: MAIA Biotechnology,
Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed May 16, 2022
                                                            File No. 333-264225

       Dear Dr. Vitoc:

              We have reviewed your amended registration statement and have the
following
       comment. In our comment, 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 comment applies 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 the comment, we may have additional comments.

       Amendment No. 2 to Registration Statement on Form S-1 filed May 16, 2022

       Business
       Strategic Collaborations and Key Agreements, page 96

   1.                                                   To the extent
applicable under your license agreements, provide risk factor disclosure that
                                                        discusses the
technology or technologies subject to march-in rights, the portion of your
                                                        business that would be
affected by the exercise of march-in rights, and whether and how
                                                        you may be compensated
in the event such rights are exercised.
 Vlad Vitoc, M.D., M.B.A.
MAIA Biotechnology, Inc.
May 23, 2022
Page 2

       You may contact Eric Atallah at 202-551-3663 or Mary Mast at
202-551-3613 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jordan Nimitz at 202-551-5831 or Christine Westbrook at 202-551-5019
with any other
questions.



                                                         Sincerely,
FirstName LastNameVlad Vitoc, M.D., M.B.A.
                                                         Division of
Corporation Finance
Comapany NameMAIA Biotechnology, Inc.
                                                         Office of Life
Sciences
May 23, 2022 Page 2
cc:       Janeane Ferrari, Esq.
FirstName LastName