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                             July 19, 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. 5 to
Registration Statement on Form S-1
                                                            Filed July 13, 2022
                                                            File No. 333-264225

       Dear Dr. Vitoc:

             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.

       Amendment No. 5 to Form S-1 filed July 13, 2022

       Capitalization, page 63

   1.                                                   It does not appear as
though you have presented your capitalization on a pro forma basis
                                                        as described in your
2nd bullet point. Please revise your filing accordingly.
   2.                                                   As a related matter it
is not clear if the issuance of the 137,420 Ratchet Shares disclosed
                                                        on pages 65 and 142 are
reflected in your pro forma capitalization table. Please revise the
                                                        filing or tell us why
no revision is necessary.
 Vlad Vitoc, M.D., M.B.A.
MAIA Biotechnology, Inc.
July 19, 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
July 19, 2022 Page 2
cc:       Janeane Ferrari, Esq.
FirstName LastName