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                              April 16, 2021

       Lindsay A. Rosenwald, M.D.
       Chief Executive Officer and President
       Fortress Biotech, Inc.
       2 Gansevoort Street, 9th Floor
       New York, New York 10014

                                                        Re: Fortress Biotech,
Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed April 12,
2021
                                                            File No. 333-255185

       Dear Dr. Rosenwald:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-3

       Incorporation of Certain Documents by Reference, page 15

   1.                                                   We note that your
registration statement incorporates by reference your Form 10-K for
                                                        the fiscal year ended
December 31, 2020, which in turn incorporates by reference certain
                                                        Part III information
from a definitive proxy statement that you have not yet filed. Please
                                                        be advised that we
cannot accelerate the effective date of your registration statement
                                                        until you have amended
your Form 10-K to include the Part III information or have filed
                                                        a definitive proxy
statement which includes such information. For guidance, please refer
                                                        to Question 123.01 of
the Securities Act Forms Compliance and Disclosure
                                                        Interpretations.
       General

   2.                                                   Based on your
disclosure that if additional sales of Journey Preferred Stock are issued,
 Lindsay A. Rosenwald, M.D.
Fortress Biotech, Inc.
April 16, 2021
Page 2
      then you will file a prospectus supplement to add the purchasers as
additional selling
      stockholders, it appears that you intend to rely on General Instruction
II.G to Form S-3 to
      omit the identities of the selling stockholders and amounts of securities
registered on their
      behalf. Please note that since you are not eligible to rely on Rule 430B
of Regulation C,
      you must file a post-effective amendment to add selling stockholders to a
registration
      statement related to a specific transaction that was completed prior to
the filing of the
      resale registration statement. Please revise your disclosure as
appropriate and include the
      amount of securities registered on behalf of each selling shareholder.
For guidance, please
      refer to Rule 430B and Regulation S-K CD&I 140.03.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Chris Edwards at 202-551-6761 or Celeste Murphy at
202-551-3257 with
any questions.



                                                            Sincerely,
FirstName LastNameLindsay A. Rosenwald, M.D.
                                                            Division of
Corporation Finance
Comapany NameFortress Biotech, Inc.
                                                            Office of Life
Sciences
April 16, 2021 Page 2
cc:       Mark F. McElreath
FirstName LastName