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                             June 14, 2021

       Bradley Saenger
       Chief Financial Officer
       Tonix Pharmaceuticals Holding Corp.
       26 Main Street, Suite 101
       Chatham, New Jersey 07928

                                                        Re: Tonix
Pharmaceuticals Holding Corp.

       Dear Mr. Saenger:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Year Ended December 31, 2020

       Results of Operations
       Fiscal year Ended December 31, 2020 Compared to Fiscal year Ended
December 31, 2019
       Research and Development Expenses, page 85

   1.                                                   You identify various
factors here that led to the increase in your research and development
                                                        expenses for the
periods presented. Please provide us proposed disclosure to be provided
                                                        in your future interim
and annual periodic reports that quantifies each of the
                                                        items identified that
explains the changes in your research and development expenses
                                                        from the prior periods.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Critical Accounting Policies and Estimates
       Research and Development, page 95

   2.                                                   Please disclose the
costs incurred during each period presented for each of your key
                                                        research and
development projects. If you do not track your research and development
                                                        costs by project,
please disclose that fact and explain why you do not maintain and
                                                        evaluate research and
development costs by project. Provide other quantitative or
 Bradley Saenger
Tonix Pharmaceuticals Holding Corp.
June 14, 2021
Page 2
         qualitative disclosure that provides more transparency as to the type
of research and
         development expenses incurred (i.e. by nature or type of expense)
which should reconcile
         to total research and development expense on the Consolidated
Statements of Operations.
       In closing, 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.

       You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 with
any questions.



FirstName LastNameBradley Saenger                            Sincerely,
Comapany NameTonix Pharmaceuticals Holding Corp.
                                                             Division of
Corporation Finance
June 14, 2021 Page 2                                         Office of Life
Sciences
FirstName LastName