United States securities and exchange commission logo

                             June 24, 2020

       Axel Bolte
       President and Chief Executive Officer
       Inozyme Pharma, Inc.
       321 Summer Street
       Suite 400
       Boston, Massachusetts 02210

                                                        Re: Inozyme Pharma,
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 12,
                                                            CIK No. 0001693011

       Dear Mr. Bolte:

             We have reviewed your amended 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

             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

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

       Prospectus Summary
       Our Solution: INZ-701, page 3

   1.                                                   We note your response
to comment 4. The pyramid graphic is not based on comparable
                                                        figures and places
disproportionate emphasis on the information it contains, and should be
                                                        further revised for
proportionality and balance. In addition, while we understand that
                                                        investors may be
interested in your potential gene therapy products, they are not
                                                        sufficiently developed
to highlight in the summary and pipeline table a this time. Revise
                                                        the table and summary
 Axel Bolte
Inozyme Pharma, Inc.
June 24, 2020
Page 2
Pipeline, page 5

2.     We note your response to prior comment 7 and that you have revised the
pipeline table to
       include your potential gene therapy program using the AAV construct, but
it does not
       appear that you have selected a development candidate or a targeted
indication for that
       program at this time, and it does not appear that you have allocated a
material portion of
       the proceeds of your offering for the development of that program. As
that program may
       be too preliminary to be emphasized in your summary and pipeline table,
please provide
       us with your analysis supporting your determination to feature that
program in your
       summary and pipeline table at this time. If this program is material,
please revise your
       table to more specifically identify the product candidate and the
targeted indication or
       revise your disclosure as appropriate.
Principal Stockholders, page 190

3.     Please revise footnote 7 to your table to identify the natural persons
who have or share
       beneficial ownership of the securities held by the Cowen Entities.
Consolidated Financial Statements
Unaudited Pro Forma Information, page F-11

4.     We note that your pro forma balance sheet reflects the issuance of the
June 2020 preferred
       stock and the conversion of all your preferred stock, inclusive of the
June 2020 preferred
       stock. However, your pro forma earnings per share calculations only
       the conversion of your preferred stock that was outstanding as of March
31, 2020. Please
       explain why you have not included the June 2020 preferred stock issuance
and conversion
       in your pro forma earnings per share calculations. In this regard, we
note that for
       transactions involving the issuance of securities subsequent to the
latest balance sheet
       presented, you should give pro forma effect to those shares as being
outstanding as of the
       beginning of the earliest period presented. Please advise or revise your
pro forma
       earnings per share information throughout the filing.
       You may contact Gary Newberry at (202) 551-3761 or Jeanne Baker at (202)
551-3691 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Abby Adams at (202) 551-6902 or Tim Buchmiller at (202) 551-3635 with
any other

FirstName LastNameAxel Bolte
                                                             Division of
Corporation Finance
Comapany NameInozyme Pharma, Inc.
                                                             Office of Life
June 24, 2020 Page 2
cc:       Brian A. Johnson, Esq.
FirstName LastName