March 27, 2020

Grant E. Pickering
President and Chief Executive Officer
SutroVax, Inc.
353 Hatch Drive
Foster City, California 94404

       Re: SutroVax, Inc.
           Amendment No. 3 to Draft Registration Statement on Form S-1
           Submitted March 13, 2020
           CIK No. 0001649094

Dear Mr. Pickering:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 3 to Draft Registration Statement on Form S-1

Prospectus Summary, page 1

1.     We note your revised disclosure in response to our prior comment 1.
Please remove your
       statements here and elsewhere in the prospectus that you believe that
SVX-24, if
       approved, has the potential to become the most broad-spectrum
pneumococcal conjugate
       vaccine addressing the $7 billion global pneumococcal vaccine market.
Please also revise
       your statements here and elsewhere in the prospectus that you believe
that you
       are developing potentially "best-in-class" vaccines. This language
implies that your
       product candidates will be effective and will be better than competing
vaccines, neither of
       which is appropriate at this stage of development.
 Grant E. Pickering
SutroVax, Inc.
March 27, 2020
Page 2

       You may contact Michael Fay at 202-551-3812 or Al Pavot at 202-551-3738
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Ada D. Sarmento at 202-551-3798 or Celeste Murphy at 202-551-3257 with any
other questions.



                                                         Sincerely,
FirstName LastNameGrant E. Pickering
                                                         Division of
Corporation Finance
Comapany NameSutroVax, Inc.
                                                         Office of Life
Sciences
March 27, 2020 Page 2
cc:       Robert W. Phillips, Esq.
FirstName LastName