March 7, 2019

Joseph Oliveto
Chief Executive Officer
Milestone Pharmaceuticals Inc.
6000 Fairview Road, Suite 1200
Charlotte, NC 28210-2252

       Re: Milestone Pharmaceuticals Inc.
           Amendment No. 1 to Draft Registration Statement
           Filed February 28, 2019
           CIK 0001408443

Dear Mr. Oliveto:

      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

Our Pipeline, page 1

1.     We note your response to comment 3. Please tell us whether you have an
active IND for
       etripamil that covers the indications atrial fibrillation and angina.
2.     We note your revised disclosure on page 76 that your research found
that, of the almost
       40% of patients who experience two or more episodes of PSVT per year
that last more
       than 10 minutes each, the findings for percentage of patients with
longer episodes and
       percentage of patients with emergency department visits decreased
between the year of
       diagnosis and the year of your research study by 13% and 29%,
respectively. Please also
       clarify your disclosure here.
 Joseph Oliveto
Milestone Pharmaceuticals Inc.
March 7, 2019
Page 2
Etripamil, page 75

3.    We note your new disclosure regarding 2017 research into the opportunity
for etripamil in
      the United States and Europe. Please provide further details and context
regarding this
      research. For example, how many PSVT patients do the physicians report as
      catheter ablation? How often do PSVT patients in the United States visit
the emergency
      room, such that 50-75% of these visits could be avoided?
        You may contact William Demarest at (202) 551-3432 or Yolanda Trotter
at (202) 551-
3472 if you have questions regarding comments on the financial statements and
matters. Please contact Chris Edwards at (202) 551-6761 or Liz Walsh at (202)
551-3696 with
any other questions.

FirstName LastNameJoseph Oliveto
                                                          Division of
Corporation Finance
Comapany NameMilestone Pharmaceuticals Inc.
                                                          Office of Healthcare
& Insurance
March 7, 2019 Page 2
cc:       Jaime L. Chase
FirstName LastName