September 11, 2019

Rahul Ballal
Chief Executive Officer
IMARA Inc.
116 Huntington Avenue, 6th Floor
Boston, MA 02116

       Re: IMARA Inc.
           Draft Registration Statement on Form S-1
           Submitted August 15, 2019
           CIK No. 0001672619

Dear Dr. Ballal:

       We have reviewed your 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.

Draft Registration Statement on Form S-1

Prospectus Summary
Implications of Being an Emerging Growth Company, page 5

1.     Please provide us with copies of all written communications, as defined
in Rule 405 under
       the Securities Act, that you, or anyone authorized to do so on your
behalf, present to
       potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they
       retain copies of the communications.
If we are unable to obtain, maintain, enforce and protect patent protection for
our technology,
page 34

2.     We note your disclosure on page 35 that you "have no issued patents
related to [your]
 Rahul Ballal
IMARA Inc.
September 11, 2019
Page 2
         SCD or b-thalassemia programs." We also note your disclosure on pages
117 through 119
         describing your patent portfolio. Please revise for consistency or
advise.
Use of Proceeds, page 68

3.       We note your disclosure that you intend to use net proceeds to advance
development of
         IMR-687 for the treatment of patients with SCD and to advance
development of IMR-687
         for the treatment of patients with b-thalassemia. Please specify how
far in the
         development of each of the listed clinical trials you expect to reach
with the proceeds of
         the offering. If any material amounts of other funds are necessary to
accomplish
         the specified purposes, state the amounts and sources of other funds
needed for each
         specified purpose and the sources. Refer to Instruction 3 to Item 504
of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies and Estimates
Stock-Based Compensation, page 90

4.       Once you have an estimated offering price or range, please explain to
us the reasons for
         any differences between the recent valuations of your common shares
leading up to the
         initial public offer and the estimated offering price. This
information will help facilitate
         our review of your accounting for equity issuances including stock
compensation.
Business
Our Solution for Sickle Cell Disease: IMR-687 as a Differentiated PDE9
Inhibitor, page 104

5.       We note your disclosure on pages 105 and 106 related to IMR-687 as
compared to
         BAY73-6691 and PF-04447943. Please tell us whether you conducted
studies on a head to
         head basis. If not, please remove the comparisons from your disclosure
or tell us why you
         believe such comparisons are appropriate. Please also disclose the
development status of
         these other PDE9 inhibitors and explain why you compared your
candidate to analogues
         of these inhibitors.
Exhibits
FirstName LastNameRahul Ballal
Comapany NameIMARA Inc.
6.     Please file the Cydan Business Services Agreement as an exhibit to the
registration
September 11, 2019tell us 2
       statement or Page why you are not required to do so.
FirstName LastName
 Rahul Ballal
FirstName LastNameRahul Ballal
IMARA Inc.
Comapany 11, 2019
September NameIMARA Inc.
Page 3
September 11, 2019 Page 3
FirstName LastName
       You may contact Bonnie Baynes at (202) 551-4924 or Sharon Blume,
Accounting
Branch Chief, at (202) 551-3474 if you have questions regarding comments on the
financial
statements and related matters. Please contact Tonya K. Aldave at (202)
551-3601 or Justin
Dobbie, Legal Branch Chief, at (202) 551-3469 with any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Healthcare
& Insurance
cc:      Cynthia T. Mazareas, Esq.