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 July 29, 2025

Ronald B. Kocak
VP Controller and Principal Accounting Officer
RenovoRx, Inc.
2570 West El Camino Real, Suite 320
Mountain View, California 94040

 Re: RenovoRx, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-Q for the quarterly period ended March 31, 2025
 File No. 001-40738
Dear Ronald B. Kocak:

 We have reviewed your July 18, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our July 10,
2025 letter.

Form 10-K for the fiscal year ended December 31, 2024
Controls and Procedures, page 87

1. We have read your response to comment 1. Notwithstanding the correction
of the typo
 referring to "December 31, 2022" which relates specifically to the
evaluation of
 disclosure controls and procedures only, you were required to provide a
management
 report on internal control over financial reporting (ICFR) beginning
with your Form
 10-K for the year ended December 31, 2023, as that was when your
transition period
 of being a newly public company ended. The information provided on pages
87-88
 under section (b) of this Item 9A. does not constitute a management
report on ICFR as
 it does not comply with the disclosure requirements of Item 308(a) of
Regulation S-K.
 Therefore, please tell us management's assessment of effectiveness of
ICFR as of
 December 31, 2024 and, as previously requested, confirm that you will
revise your
 future filings to provide management s conclusion regarding the
effectiveness of your
 July 29, 2025
Page 2

 internal control over financial reporting.

Form 10-Q for the quarterly period ended March 31, 2025
Item 2: Management's Discussion and Analysis of Financial Condition and Results
of
Operations, page 16
Results of Operations, page 20, page 90

2. We have read your response to comment 2. You have told us, among other
things, that
 "all commercial costs for the production of the RenovoCath device in
connection with
 our commercialization program are capitalized on the balance sheet or
charged as cost
 of goods sold on the income statement." However, you disclose on page 21
that you
 anticipate selling, general and administrative expenses to increase
during 2025 as you
 progress with your commercialization activities for your RenovoCath
device. Please
 address the following:
 Please tell us the amount and the nature of the commercial costs
that were charged
 to cost of goods sold for the four most recent quarters and explain
how these costs
 are appropriately classified as cost of goods sold. Refer to ASC
330-10-30.
 Consider enhancing your disclosure of these amounts in future
filings.
 Also, tell us and consider revising your future filings to identify
the nature of the
 increased expenses in selling, general and administrative related to
the
 commercialization of your RenovoCath device.

 Please contact Jenn Do at 202-551-3743 or Vanessa Robertson at
202-551-3649 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
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