SecProbe.io

CORRESP
 1
 filename1.htm

 Sharps
Technology, Inc.

 105
Maxess Road,

 Melville,
NY 11747

 VIA
EDGAR

 December
23, 2025

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Energy & Transportation

 Washington,
D.C. 20549

 Attn:
 Juan
 Grana

 Katherine
 Bagley

 Re: Sharps
 Technology, Inc.
 Registration
 Statement on Form S-3

 Filed
 September 15, 2025

 File
No. 333-290255

 Ladies
and Gentleman:

 Sharps
Technology, Inc. (the " Company ") hereby transmits its response to the comment letter received from the staff (the
" Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") on November 26, 2025
relating to the Registration Statement on Form S-3, filed by the Company with the Commission on September 15, 2025.

 For
the Staff's convenience, we have repeated below the Staff's comment in bold and have followed such comment with the Company's
response. Disclosure changes made in response to the Staff's comment have been made in Amendment No. 1 to Registration Statement
on Form S-3 (the " Registration Statement ") which is being submitted to the Commission contemporaneously with the submission
of this letter.

 Registration
Statement on Form S-3

 General

 1.
 We
 note your disclosure that you have adopted a Treasury Policy under which the principal holding
 in your treasury reserve on the balance sheet will be allocated to digital assets, starting
 with SOL, as well as your disclosure that you do not intend to allocate treasury assets to
 other digital assets in the near term. We also note that the financial statements included
 in your Form 10-Q for the period ended September 30, 2025 include USDC and USDT holdings.
 Please revise your disclosure to:

 ●
 Provide
 greater details regarding any plans to acquire and hold digital assets, including in what proportions and the anticipated timeline.
 In addition, please revise to provide a definition or more detailed explanation for what you mean by the term "digital assets."
 Please ensure that your revised disclosure clarifies the scope of the term and the type of digital assets it may cover, as well as
 the different characteristics, attributes and risk profiles associated with all included categories of digital assets.

 ●
 Provide
 a discussion of the material aspects of your treasury strategy and how you intend to generate profit through this strategy.

 Response:
The Company acknowledges the Staff's comment and has revised the Registration Statement accordingly. Please see pages 1 through
5 of the Registration Statement for further details.

 2.
 Please
 revise to provide additional disclosure regarding SOL and your staking plans. For example purposes only:

 ●
 Disclose
 your policies and procedures regarding your plans to stake Solana, including how much of your SOL you intend to stake.

 ●
 Revise
 to provide greater detail explaining how agreements with staking providers will operate.

 ●
 If
 material, add a risk factor addressing any liquidity risks related to your staking plans.

 ●
 Identify
 the custodians that hold and will hold your digital assets and disclose the material terms of the custody arrangements, including
 the amount and limitations of any insurance coverage.

 Response:
The Company acknowledges the Staff's comment and has revised the Registration Statement accordingly. Please see pages 2 through
7 of the Registration Statement for further details.

 3.
 We
 note that your Form 8-K furnished September 2, 2025 discloses that you entered into Consulting and Strategic Advisor Agreements on
 August 28, 2025. Please disclose how compensation for SOL Edge Ltd will be calculated. Please also disclose the material terms of
 the Investment Guidelines.

 Response:
The Company acknowledges the Staff's comment and has revised the Registration Statement accordingly. Please see page 2 of
the Registration Statement for further details.

 *
* *

 We
thank you for your review of the foregoing and the Registration Statement. If you have further comments, please feel free to contact
to our counsel, Jonathan Deblinger, Esq. at jdeblinger@egsllp.com or by telephone at (212) 370-1300.

 Sincerely,

 /s/
 Paul Danner

 Name:
 Paul
 Danner

 Title:
 Principal
 Executive Officer

 cc:
 Jonathan
 Deblinger, Esq.

 Ellenoff
 Grossman & Schole LLP