October 25, 2019

Steven Gullans, Ph.D.
President & Chief Executive Officer
Gemphire Therapeutics Inc.
P.O. Box 130235
Ann Arbor, MI 48113

       Re: Gemphire Therapeutics Inc.
           Amendment No. 1 to Registration Statement on Form S-4
           Filed October 11, 2019
           File No. 333-233588

Dear Dr. Gullans:

      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. Unless
we note
otherwise, our references to prior comments are to comments in our October 2,
2019 letter.

Amendment No. 1 to Registration Statement on Form S-4 filed on October 11, 2019

Risk Factors
Risks Related to Gemphire Common Stock
Gemphire's amended and restated bylaws designate the Court of Chancery of the
State of
Delaware as to the sole and exclusive forum..., page 89

1.     We note your response to comment 2, which we reissue in part. Please
ensure that the
       exclusive forum provision in your bylaws includes a statement to the
effect that the
       provision is not intended to apply to any actions arising under the
Exchange Act or
       Securities Act or the rules and regulations promulgated thereunder, or
tell us how you will
       inform investors in future filings that the provision is not intended to
apply to such
       claims.
 Steven Gullans, Ph.D.
Gemphire Therapeutics Inc.
October 25, 2019
Page 2
U.S. Federal Income Tax Consequences of the Merger to U.S. Holders of NeuroBo
Common
Stock, page 184

2.     We note your statement that the disclosure in this section constitutes
the opinion of
       counsel as to the tax consequences of the merger, and that the parties
"intend" for the
       merger to be treated as a tax-free contribution or a reorganization. We
further note that
       this section describes the tax consequences to holders "assuming the
qualification
       of the merger as a tax-free contribution or a reorganization." However,
in Exhibit 8.2,
       counsel confirms that "the merger shall qualify either as a tax-free
contribution pursuant
       to Section 351 of the Code, or as a 'reorganization' within the meaning
of
       Section 368(a) of the Code." The disclosure constituting the opinion
should
       should clearly identify each material tax consequence to holders being
opined upon, and
       set forth an opinion as to each identified tax item and the basis for
the opinion. It is
       inappropriate to assume any legal conclusion underlying the opinion. For
guidance,
       please refer to Sections III.C.1 and III.C.3 of Staff Legal Bulletin No.
19.
Agreements Related to the Merger
Contingent Value Rights Agreement, page 209

3.     We note your response to comment 5, which we reissue in part. Although
the tax
       treatment of the Contingent Value Rights (CVRs) may be subject to
uncertainty, counsel
       must opine on each material tax consequence and may provide a "should"
or "more likely
       than not" opinion and describe the related uncertainty where a "will"
opinion is not given.
       Accordingly, please revise your disclosure to provide an opinion as to
the tax
       consequences of the receipt of the CVRs to Gemphire shareholders.
NeuroBo Business
Intellectual Property, page 308

4.     We note your response to comment 13. Please expand your disclosure to
provide the
       expiry dates for NeuroBo's issued patents.
       You may contact Ibolya Ignat at 202-551-3636 or Sharon Blume at
202-551-3474 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Christine Westbrook at 202-551-5019 or Mary Beth Breslin at
202-551-3625 with any
other questions.



                                                             Sincerely,
FirstName LastNameSteven Gullans, Ph.D.
                                                             Division of
Corporation Finance
Comapany NameGemphire Therapeutics Inc.
                                                             Office of Life
Sciences
October 25, 2019 Page 2
cc:       Phillip D. Torrence, Esq.
FirstName LastName