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                              July 12, 2023

       Morgan Frank
       Interim Chief Executive Officer
       SANUWAVE Health, Inc.
       11495 Valley View Road
       Eden Prairie, Minnesota 55344

                                                        Re: SANUWAVE Health,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed June 30, 2023
                                                            File No. 333-273060

       Dear Morgan Frank:

              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.

       Registration Statement on Form S-1

       Incorporation of Certain Information by Reference, page 16

   1.                                                   Please tell us why you
are eligible to incorporate by reference. In this regard, we note the
                                                        risk factor disclosure
in your 10-K for the fiscal year ended December 31, 2022 that your
                                                        common stock is
considered a penny stock. Therefore, it appears that you may currently
                                                        be, or may have been, a
registrant for an offering of penny stock within the past three
                                                        years. Please refer to
General Instruction VII.D.1(c) of Form S-1. Alternatively, revise
                                                        your reference to
incorporation by reference and provide all required disclosure within the
                                                        prospectus.
 Morgan Frank
FirstName  LastNameMorgan
SANUWAVE      Health, Inc. Frank
Comapany
July       NameSANUWAVE Health, Inc.
     12, 2023
July 12,
Page  2 2023 Page 2
FirstName LastName
        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.

       Please contact Jessica Ansart at 202-551-4511 or Katherine Bagley at
202-551-2545 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:      Ben Stacke