United States securities and exchange commission logo





                          June 9, 2020

       Vincent J. Milano
       Chief Executive Officer
       Idera Pharmaceuticals, Inc.
       505 Eagleview Blvd., Suite 212
       Exton, PA 19341

                                                        Re: Idera
Pharmaceuticals, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed June 2, 2020
                                                            File No. 333-238868

       Dear Mr. Milano:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Ada D.
Sarmento at 202-551-3798 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              Joanne R. Soslow, Esq.