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                               May 7, 2020

       Darrin R. Uecker
       President, Chief Executive Officer and Director
       Pulse Biosciences, Inc.
       3957 Point Eden Way
       Hayward, CA 94545

                                                        Re: Pulse Biosciences,
Inc.
                                                            Amendment No. 4 to
Registration Statement on Form S-3
                                                            Filed May 7, 2020
                                                            File No. 333-237577

       Dear Mr. Uecker:

             We have reviewed your amended registration statement and have the
following
       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 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.

       Amendment No. 4 to Registration Statement on Form S-3 filed May 7, 2020

       Cover Page

   1.                                                   We note your response
to our oral comment issued May 6, 2020. Although Rule 430A of
                                                        the Securities Act of
1933 permits registrants to omit certain pricing-related information
                                                        from a registration
statement that is declared effective, your filing must include the
                                                        principal amount of
securities to be offered in a pre-effective amendment. Accordingly,
                                                        revise your
registration statement to disclose the total number of units you are
registering,
                                                        rather than registering
a dollar amount. For guidance, refer to Question 227.02 of
                                                        Compliance and
Disclosure Interpretations for Securities Act Rules.
 Darrin R. Uecker
FirstName LastNameDarrin R. Uecker
Pulse Biosciences, Inc.
Comapany NamePulse Biosciences, Inc.
May 7, 2020
Page 2
May 7, 2020 Page 2
FirstName LastName
       You may contact Jeffrey Gabor at 202-551-2544 or Celeste Murphy at
202-551-3257
with any questions.



                                                       Sincerely,

                                                       Division of Corporation
Finance
                                                       Office of Life Sciences
cc:      Andrew D. Hoffman, Esq.