July 15, 2019






United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549


 Re:Tonix Pharmaceuticals Holding Corp.

Registration Statement on Form S-1 (File No. 333-232195)


Ladies and Gentlemen:


As the underwriter of the proposed offering of Tonix Pharmaceuticals Holding Corp. (the “Company”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:30 p.m., Eastern Standard Time, on July 15, 2019, or as soon thereafter as is practicable.


The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.


  Very truly yours,
  By: /s/ David W. Boral
    Name: David W. Boral
    Title: Co- Head of Investment Banking,
  By: /s/ Joseph T. Rallo
    Name: Joseph T. Rallo
    Title: Co-Head of Investment Banking