| Roth Capital Partners, LLC | National Securities Corporation |
| 888 San Clemente Drive | 120 Broadway, 27th Floor |
| Newport Beach, CA 92660 | New York, NY 10271 |
July 24, 2013
VIA EDGAR
United States Securities
and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Adam Turk, Esq.
| Re: | Tonix Pharmaceuticals Holding Corp. |
Registration Statement on Form S-1
File No. 333-188547
Ladies and Gentlemen:
The undersigned hereby join in the request of the Company to withdraw the request for acceleration dated July 22, 2013, of the effective date of the registration statement referred to above that was requested to become effective at 4:00 p.m., Washington D.C. time, on Wednesday, July 24, 2012, or as soon thereafter as practicable.
| Roth Capital Partners, LLC | NATIONAL SECURITIES CORPORATION | |||
| By: | /s/ Aaron Gurewitz | By: | /s/ Jonathan Rich | |
| Name: | Aaron Gurewitz | Name: | Jonathan Rich | |
| Title: | Head of Equity Capital Markets | Title: | Head of Investment Banking | |