September 11, 2019 Brian Dow Chief Financial Officer Pulse Biosciences, Inc. 3957 Point Eden Way Hayward, CA 94545 Re: Pulse Biosciences, Inc. Form 10-K for the Year Ended December 31, 2018 Filed March 14, 2019 File No. 001-37744 Dear Mr. Dow: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Electronics and Machinery