March 20, 2019

Shoshana Shendelman
President and Chief Executive Officer
Applied Therapeutics, Inc.
340 Madison Avenue
New York, New York 10173

       Re: Applied Therapeutics, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted March 8, 2019
           CIK No. 0001697532

Dear Dr. Shendelman:

      We have reviewed your amended draft registration statement and have the
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

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

Prospectus Summary
Our Pipeline, page 3

1.     We note your response to comment 2 and your revised pipeline table. We
also note that
       you have extended the first arrow halfway into Phase 2, which seems
inconsistent with
       your disclosure that the Phase 2/3 clinical trial is to be initiated
later this year. Please
       revise for consistency or advise us why such revision is not necessary.
Market and Industry Data, page 56

2.     We note your revised disclosure in response to comment 6 and reissue in
part our prior
       comment. The disclosure provides that information from industry
publications and other
 Shoshana Shendelman
Applied Therapeutics, Inc.
March 20, 2019
Page 2
      third-party sources is inherently imprecise. This statement may imply an
      disclaimer of responsibility with respect to such information. Please
revise to state clearly
      that you are liable for such information or delete the statement.
Certain Relationships and Related Party Transactions, page 140

3.    We note your disclosure here and on page F-27 regarding your second
license agreement
      with Columbia University. In the Business section, please disclose the
principal terms of
      this agreement or include a cross-reference to the description in the
notes to the financial
      statements. Please also file this agreement as an exhibit or explain to
us why such
      agreement is not required to be filed. Finally, please ensure that your
disclosure regarding
      the two Columbia agreements is clear and consistent throughout the
prospectus by, for
      example, using consistent defined terms to refer to the two agreements.
4.    Footnote 2 to the table on page 142 discloses that Mr. Ilyadzhanov has
voting and
      investment power over the shares owned by E Squared Investment Fund, LLC.
      revise to disclose Mr. Ilyadzhanov's full name and the basis on which he
is a related
      person. See Item 404(a) of Regulation S-K.
Principal Stockholders, page 145

5.    In the principal stockholder table on page 145, please disclose the names
of the funds
      affiliated with E Squared Investment Fund, LLC that hold securities in
the company.
      Please also disclose the name(s) of the natural person(s) that have
ultimate voting or
      dispositive control over such securities. See Item 403 of Regulation S-K.
Index to Financial Statements, page F-1

6.    We note the disclosure in the "Related Parties" section on page F-26 that
describes the
      LaunchLabs Agreement. Please include this agreement in the "Certain
Relationships and
      Related Party Transactions" section of the prospectus or advise us why
such disclosure is
      not required. See Item 404 of Regulation S-K.

       You may contact Mark Rakip at 202-551-3573 or William Demarest at
202-551-3432 if
you have questions regarding comments on the financial statements and related
matters. Please
contact David Plattner at 202-551-8094 or Tom Kluck at 202-551-3233 with any
other questions.

FirstName LastNameShoshana Shendelman
                                                            Division of
Corporation Finance
Comapany NameApplied Therapeutics, Inc.
                                                            Office of
Healthcare & Insurance
March 20, 2019 Page 2
cc:       Divakar Gupta, Esq.
FirstName LastName