Mail Stop 3030
                                                                   December 19,
2018

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

            Re:    SANUWAVE Health, Inc.
                   Amendment No. 8 to Registration Statement on Form S-1
                   Filed December 6, 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 October
4, 2018 letter.

     Calculation of Registration Fee

     1.     Please expand your response to prior comments 1 and 2 to tell us
whether any of the
            shares included in the fee table remain registered for sale by any
other registration
            statement. In this regard we note footnote 5 to the fee table in
your amendment to this
            registration statement filed September 14, 2018 and the pending
post-effective
            amendments to previous registration statements.

     Risk Factors, page 7

     2.     We note your response to prior comments 4 and 5 and your
deregistration by post-
            effective amendment filed in September 2016. If a sufficient amount
of securities were
            not initially registered for sale, please tell us whether your
disclosure regarding 10
            warrant holders on page 7 reflects all securities that were not
registered for sale since the
 Kevin A. Richardson, II
SANUWAVE Health, Inc.
December 19, 2018
Page 2

       securities were first offered and sold as well any securities that were
offered or sold after
       they were deregistered.

Selling Stockholders, page 24

3.     From the revised footnotes to the Selling Stockholders table, it is
unclear how the offered
       securities were acquired by the relevant selling stockholder and how the
amount offered
       ties to the amount registered and your disclosure regarding the relevant
transactions. We
       note for example footnotes 5 and 10. Please revise 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:    Murray Indick, Esq.
       Morrison Foerster LLP