SEC Company Response from Tonix Pharmaceuticals Holding Corp. (TNXP) (CIK 0001430306) (TNXP) — Jul 24, 2013

Tonix Pharmaceuticals Holding Corp. (TNXP) (CIK 0001430306)
Date: July 24, 2013 · CIK: 0001430306 · Accession: 0001144204-13-040931

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File numbers found in text: 333-188547

Date

July 24, 2013

Author

Aaron Gurewitz

Form

CORRESP

Company

Tonix Pharmaceuticals Holding Corp. (TNXP) (CIK 0001430306)

Letter

Roth Capital Partners, LLC National Securities Corporation

888 San Clemente Drive 120 Broadway, 27th Floor

Newport Beach, CA 92660 New York, NY 10271

July 24, 2013

VIA EDGAR

United States Securities

and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Adam Turk, Esq.

Re: Tonix Pharmaceuticals Holding Corp.

Registration Statement on Form S-1

File No. 333-188547

Ladies and Gentlemen:

The undersigned hereby join in the request of the Company to withdraw the request for acceleration dated July 22, 2013, of the effective date of the registration statement referred to above that was requested to become effective at 4:00 p.m., Washington D.C. time, on Wednesday, July 24, 2012, or as soon thereafter as practicable.

Roth Capital Partners, LLC

NATIONAL SECURITIES CORPORATION

By: /s/ Aaron Gurewitz

By: /s/ Jonathan Rich

Name: Aaron Gurewitz

Name: Jonathan Rich

Title: Head of Equity Capital Markets

Title: Head of Investment Banking

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CORRESP
1
filename1.htm

    Roth Capital Partners, LLC
    National Securities Corporation

    888 San Clemente Drive
    120 Broadway, 27th Floor

    Newport Beach, CA 92660
    New York, NY 10271

July 24, 2013

VIA EDGAR

United States Securities

 and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Adam Turk, Esq.

 Re: Tonix Pharmaceuticals Holding Corp.

Registration Statement on Form
S-1

File No. 333-188547

Ladies and Gentlemen:

The undersigned hereby
join in the request of the Company to withdraw the request for acceleration dated July 22, 2013, of the effective date of the registration
statement referred to above that was requested to become effective at 4:00 p.m., Washington D.C. time, on Wednesday, July
24, 2012, or as soon thereafter as practicable.

    Roth Capital Partners, LLC

    NATIONAL SECURITIES CORPORATION

    By:
    /s/ Aaron Gurewitz

    By:
    /s/ Jonathan Rich

    Name:
     Aaron Gurewitz

    Name:
     Jonathan Rich

    Title:
     Head of Equity Capital Markets

    Title:
     Head of Investment Banking

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