Mail Stop 3030

                                                                 December 19,
2016

     Kevin A. Richardson, II
     Acting Chief Executive Officer
     SANUWAVE Health, Inc.
     3360 Martin Farm Road, Suite 100
     Suwanee, Georgia 30024

            Re:    SANUWAVE Health, Inc.
                   Amendment No. 1 to Registration Statement on Form S-1
                   Filed December 5, 2016
                   File No. 333-213774

     Dear Mr. Richardson:

            We have limited our review of your amended registration statement
to those issues we
     have addressed in our 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.

     Calculation of Registration Fee

     1.     We note your reference to other registration statements in the
paragraph following the
            footnotes to your fee table. Please provide us a table that shows
clearly which of each
            selling security holder's offered securities mentioned in your
disclosure beginning on
            page 20 were registered for sale on each of the registration
statements mentioned in that
            paragraph, and which are registered for sale by this registration
statement. Ensure that
            the figures in the table that you provide in response to this
comment are clearly
            reconcilable to the Selling Stockholders' section of this
prospectus, the prospectus in
            each of the relevant prior registration statements, the numbers in
the fee table of this
            registration statement, and the numbers in the paragraph following
the footnotes to your
            fee table in this registration statement.
 Kevin A. Richardson, II
SANUWAVE Health, Inc.
December 19, 2016
Page 2

Where You Can Find More Information, page 62

2.     If you are eligible and elect to incorporate information by reference
pursuant to General
       Instruction VII of Form S-1, please specifically identify in your
"incorporation by
       reference" disclosure in this prospectus each report filed pursuant to
Section 13(a) or
       15(d) of the Exchange Act since December 31, 2015. See Form S-1 Item
12(a)(2).

Exhibit 23.1

3.     We note that the audit report on page F-19 of the prospectus is dated
March 30, 2016, but
       the consent filed as Exhibit 23.1 refers to a report dated September 30,
2016. Please file
       a consent that references the report that has been included and
incorporated in the
       prospectus.

       Please contact Tim Buchmiller at (202) 551-3635 or me at (202) 551-3617
with any
questions.

                                                            Sincerely,

                                                            /s/ Russell Mancuso

                                                            Russell Mancuso
                                                            Branch Chief
                                                            Office of
Electronics and Machinery


cc:    John C. Ethridge, Jr., Esq.
       Smith, Gambrell & Russell, LLP