July 31, 2019

Christopher Capelli, M.D.
Chief Executive Officer
Soliton, Inc.
5304 Ashbrook Drive
Houston, Texas 77081

       Re: Soliton, Inc.
           Registration Statement on Form S-1
           Response dated July 30, 2019
           File No. 333-232483

Dear Dr. Capelli:

       We have reviewed your July 30, 2019 response to our comment letter and
have the
following 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 reference to prior comments are to comments in our July 26, 2019
letter.

Response letter dated July 30, 2019

Certificate of Incorporation and Bylaws Provisions, page 9

1.     We note your proposed disclosure that "[t]his provision would not apply
to suits brought
       to enforce a duty or liability created by the Exchange Act or any other
claim for which the
       U.S. federal courts have exclusive jurisdiction." In our prior comment
1, we noted that
       Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
       over all suits brought to enforce any duty or liability created by the
Securities Act or the
       rules and regulations thereunder. If your forum selection provision
applies to Securities
       Act claims, please also revise your prospectus to state that there is
uncertainty as to
       whether a court would enforce such provision and that investors cannot
waive compliance
       with the federal securities laws and the rules and regulations
thereunder. If this provision
 Christopher Capelli, M.D.
Soliton, Inc.
July 31, 2019
Page 2
      does not apply to actions arising under the Securities Act, please also
ensure that the
      exclusive forum provision in the governing documents states this clearly,
or tell us how
      you will inform investors in future filings that the provision does not
apply to any actions
      arising under the Securities Act.
      Please contact Thomas Jones at 202-551-3602 or Tim Buchmiller, Senior
Attorney, at
202-551-3635 with any questions.



                                                            Sincerely,
FirstName LastNameChristopher Capelli, M.D.
                                                            Division of
Corporation Finance
Comapany NameSoliton, Inc.
                                                            Office of
Electronics and Machinery
July 31, 2019 Page 2
cc:       Cavas S. Pavri, Esq.
FirstName LastName