Mail Stop 3030

                                                                  May 8, 2018

     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. 4 to Registration Statement on Form S-1
                   Filed April 19, 2018
                   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.
Unless we note
     otherwise, our references to prior comments are to comments in our March
12, 2018 letter.

     Calculation of Registration Fee

     1.     It is generally inconsistent with Section 5 of the Securities Act
to register a transaction
            that you began without registration. Therefore, it is unclear how
it is consistent with
            Section 5 to register on this registration statement the exercise
of outstanding warrants.
            Please advise or revise.

     2.     We note your revisions in response to prior comments 1 and 2. Given
the dollar amount
            of securities registered for sale on your registration statement
declared effective February
            16, 2016 and dollar amount deregistered by your post-effective
amendment filed
            September 23, 2016, it is unclear how you have securities that
remain registered for sale
            on that registration statement for which a Rule 429 prospectus can
be used. For
 Kevin A. Richardson, II
SANUWAVE Health, Inc.
May 8, 2018
Page 2

       guidance, see the Division of Corporation Finance's Securities Act Rules
Compliance
       and Disclosure Interpretation 240.05. Please advise or revise.

3.     We note your response to prior comment 3. However, your registration
statement on
       Form S-1 file number 333-195263 appears to relate to the resale of
common stock, while
       the prospectus in this registration statement appears to describe the
transaction registered
       by that registration statement as your issuance of common stock upon the
exercise of
       warrants. Please clarify.

Prospectus

4.     We note that you have moved your financial statements so that they now
appear outside
       of your prospectus. Please include your financial statements within your
prospectus as
       appropriate.

       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