January 17, 2020

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

       Re: SutroVax, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted December 31, 2019
           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. 1 to Draft Registration Statement on Form S-1

Prospectus Summary, page 1

1.     We note your response to our prior comment 1 and continue to object to
your
       characterization of SVX-24 as having "the potential to become the
standard of care." The
       qualifier, "if approved," does not address our concerns that this
language continues to
       imply that the product will be effective and will replace the current
standard of care before
       a competing vaccine does, neither of which is appropriate at this stage
of development.
       Please revise your registration statement to remove this language.
 Grant E. Pickering
FirstName Inc.
SutroVax, LastNameGrant E. Pickering
Comapany NameSutroVax, Inc.
January 17, 2020
Page 2
January 17, 2020 Page 2
FirstName LastName
Risk Factors Summary, page 5

2.       We note your response to our prior comment 5 and reissue. The risk
that your intended
         approach will not be sufficient for regulatory approval or that
regulators will require field
         efficacy trials or longer trials with more participants than you
currently anticipate exists
         now. Please add a separate bullet point in this section to discuss
that risk.
       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 Mary Beth Breslin at 202-551-3625 with any
other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Life
Sciences
cc:      Robert W. Phillips, Esq.