November 9, 2018 Anthony DiTonno Chief Executive Officer Tenax Therapeutics, Inc. ONE Copley Parkway, Suite 490 Morrisville, NC 27560 Re: Tenax Therapeutics, Inc. Registration Statement on Form S-1 Filed November 6, 2018 File No. 333-228212 Dear Mr. DiTonno: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Ronald E. Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining cc: Margaret Rosenfeld