United States securities and exchange commission logo





                             July 16, 2020

       Thomas J. Schuetz, M.D., Ph.D.
       Chief Executive Officer
       Compass Therapeutics, Inc.
       245 First Street
       3rd Floor
       Cambridge, Massachusetts 02142

                                                        Re: Compass
Therapeutics, Inc.
                                                            Form 8-K
                                                            Filed June 23, 2020
                                                            File No. 000-55939

       Dear Dr. Schuetz:

              We have reviewed your filing 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 8-K filed June 23, 2020

       Description of Business, page 9

   1.                                                   Throughout this
section, please remove all statements that reference efficacy and safety,
                                                        including synonyms and
similar terms (e.g., "robust" and "potent cytotoxic activity"), as
                                                        safety and efficacy
determinations are solely within the authority of the Food and Drug
                                                        Administration or other
regulatory agencies.
       Overview, page 9

   2.                                                   We note that you state
that you "plan to rapidly advance [your] product candidates
                                                        through clinical
development." Please revise your disclosure here and throughout your
                                                        filing to remove any
implication that you will be successful in commercializing your
                                                        product candidates in a
rapid or accelerated manner, as such statements are speculative.
 Thomas J. Schuetz, M.D., Ph.D.
FirstName  LastNameThomas
Compass Therapeutics, Inc. J. Schuetz, M.D., Ph.D.
Comapany
July       NameCompass Therapeutics, Inc.
     16, 2020
July 16,
Page  2 2020 Page 2
FirstName LastName
Pipeline, page 11

3.       Please revise the chart on page 11 to clarify the term "TAA" and
provide a brief narrative
         below of what this line in the chart is depicting. Please also include
the specific
         indication(s) for which your product candidates are being developed.
Figure 1. We have assembled a panel of proprietary antibodies against a broad
panel of key
immune targets, page 13

4.       Please provide a brief narrative of what your graphic is depicting.
Phase 1 clinical trial data as of May 24, 2020, page 20

5.       We note your disclosure that the ongoing Phase 1 trial of CTX-471 was
designed to
         evaluate the safety and tolerability of your product candidate, but it
appears that you are
         presenting efficacy data from this trial on page 21. Please revise to
remove the statements
         regarding efficacy if it is not being measured in the current trial,
or revise to clarify the
         current trial phase and disclose the efficacy endpoints of the trial.
License Agreement, page 29

6.       Please disclose that you have additional milestone payments due under
your collaboration
         agreement and quantify the aggregate potential milestone payments due.
Management's Discussion and Analysis of Financial Condition and Results of
Operation
Overview, page 99

7.       We note you will need substantial additional funding to support your
continuing
         operations and pursue your growth strategy. Please disclose how far in
the development
         of your product candidates you expect to reach with your current
capital resources.
Results of Operations, page 104

8.       We note that you have multiple products in varying stages of
development and clinical
         testing. Please revise to disclose more detail for your research and
development expenses
         each period presented, including but not limited to by product
candidate and the nature of
         the expenses.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 Thomas J. Schuetz, M.D., Ph.D.
Compass Therapeutics, Inc.
July 16, 2020
Page 3

       You may contact Eric Atallah at 202-551-3663 or Brian Cascio at
202-551-3676 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Courtney Lindsay at 202-551-7237 or Mary Beth Breslin at 202-551-3625
with any other
questions.



FirstName LastNameThomas J. Schuetz, M.D., Ph.D.         Sincerely,
Comapany NameCompass Therapeutics, Inc.
                                                         Division of
Corporation Finance
July 16, 2020 Page 3                                     Office of Life
Sciences
FirstName LastName