November 28, 2018

Francis P. Grillo
President and Chief Executive Officer
AirXpanders, Inc.
3047 Orchard Parkway
San Jose, California 95134

       Re: AirXpanders, Inc.
           Registration Statement on Form S-1
           Filed November 1, 2018
           File No. 333-228100

Dear Mr. Grillo:

       We have limited our review of your 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.

Form S-1 filed November 1, 2018

Incorporation of Certain Information by Reference, page 10

1.     Please revise your incorporation by reference section to incorporate by
reference the Form
       8-K filed on October 25, 2018.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Francis P. Grillo
AirXpanders, Inc.
November 28, 2018
Page 2

      Please contact Thomas Jones at 202-551-3602 or Amanda Ravitz, Assistant
Director, at
202-551-3412 with any questions.



                                                         Sincerely,
FirstName LastNameFrancis P. Grillo
                                                         Division of
Corporation Finance
Comapany NameAirXpanders, Inc.
                                                         Office of Electronics
and Machinery
November 28, 2018 Page 2
cc:       Mark B. Weeks
FirstName LastName