Tonix Pharmaceuticals Holding Corp.

509 Madison Avenue, Suite 1608

New York, New York 10022


September 9, 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. 333-233445) 


Ladies and Gentlemen:


In accordance with Rule 461 under the Securities Act of 1933, as amended, Tonix Pharmaceuticals Holding Corp. (the “Company”) hereby requests that the above-referenced Registration Statement (the “Registration Statement”) be declared effective by the Securities and Exchange Commission (the “Commission”) at 4:30 p.m., Eastern Standard Time, on September 11, 2019, or as soon as practicable thereafter.


Please call Alan Wovsaniker of Lowenstein Sandler LLP at (973) 597-2564 to confirm the effectiveness of the Registration Statement or with any questions.


[Signature page follows.]




U.S. Securities and Exchange Commission

September 9, 2019

Page 2 


  Very truly yours,
  By: /s/ Bradley Saenger  
  Name: Bradley Saenger
  Title: Chief Financial Officer



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