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CORRESP
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Tonix Pharmaceuticals Holding Corp.

509 Madison Avenue, Suite 306

New York, New York 10022

August 6, 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:

Pursuant to Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Tonix Pharmaceuticals
Holding Corp. (the “Company”) respectfully requests that the effective date of the registration statement referred
to above be accelerated so that it will become effective at 4:00 p.m., Eastern Standard Time, on Thursday, August 8, 2013, or as
soon thereafter as possible. The Company acknowledges that: 1) should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and 3) the Company
may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.

    TONIX PHARMACEUTICALS HOLDING CORP.

    By:
    /s/ SETH LEDERMAN

    Name:
    Seth Lederman

    Title:
    Chief Executive Officer