SecProbe.io

CORRESP
 1
 filename1.htm

 Dawson
James Securities, Inc.

 101
North Federal Highway, Suite 600

 Boca
Raton, Fl 33432

 May
14, 2025

 VIA
EDGAR CORRESPONDENCE

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E. Washington, D.C. 20549

 Re: NanoVibronix,
 Inc.
 Registration Statement on Form S-1/A

 File
No. 333-284973

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), we, the placement
agent, hereby request that the Securities and Exchange Commission (the "Commission") take appropriate action to cause the
above-referenced registration statement on Form S-1/A (the "Registration Statement") to become effective at 4:00 p.m., Eastern
Time, on Wednesday, May 14, 2025 or as soon thereafter as practicable.

 Pursuant
to Rule 460 under the Act, we wish to advise you that we have distributed as many copies of the Preliminary Prospectus dated May 14,
2025 to agents, dealers, institutions and others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

 The
undersigned, as placement agent, has complied and will comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 If
you require any additional information with respect to this letter, please contact Ali Panjwani at (212) 326-0820 of Pryor Cashman LLP.

 Very truly yours,

 DAWSON JAMES
 SECURITIES, INC.

 By:
 /s/
 Robert D. Keyser, Jr.

 Robert D. Keyser, Jr.

 Chief Executive Officer

 cc: M.
 Ali Panjwani, Esq.

 Pryor
Cashman LLP

CORRESP
 1
 filename1.htm

 NanoVibronix,
Inc.

 969
Pruitt Place

 Tyler
TX 75703

 May
14, 2025

 VIA
EDGAR

 Division
of Corporation Finance

 Office
of Industrial Applications and Services

 U.S.
Securities and Exchange Commission

 Washington,
D.C. 20549

 Attention:
Jane Park

 Re:
 NanoVibronix,
 Inc.
 Registration
 Statement on Form S-1
 Originally
 filed on February 14, 2025, as amended on April 22, 2025, April 29, 2025, May 12, 2025, and May 14, 2025
 File
 No. 333-284973 (as amended, the "Registration Statement")
 Request
 for Acceleration

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the " Commission ") under
the Securities Act of 1933, as amended, NanoVibronix, Inc. (the " Company "), hereby respectfully requests acceleration
of the effective date of the Registration Statement, so that it may become effective at 4:00 p.m., Eastern Time, on May 14, 2025, or
as soon thereafter as practicable.

 Should
any member of the staff of the Commission have any questions or comments with respect to this request, please contact our counsel, Haynes
and Boone, LLP, attention: Alla Digilova, Esq. at (212) 659-4993.

 Very truly yours,

 Nanovibronix,
 Inc.

 By:
 /s/ Stephen
 Brown

 Stephen Brown

 Chief Financial Officer

 cc:
 Alla Digilova, Esq., Haynes and Boone, LLP

February 20, 2025
Brian Murphy
Chief Executive Officer
NanoVibronix, Inc.
969 Pruitt Place
Tyler, TX 75703
Re:NanoVibronix, Inc.
Registration Statement on Form S-1
Filed February 14, 2025
File No. 333-284973
Dear Brian Murphy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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.
            Please contact Jane Park at 202-551-7439 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Alla Digilova, Esq.

CORRESP
1
filename1.htm

NanoVibronix,
Inc.

525
Executive Boulevard

Elmsford,
New York 10523

September
19, 2023

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Industrial Applications and Services

Securities
and Exchange Commission

Washington,
D.C. 20549

Attention:
Nicholas O’Leary

    Re:
    NanoVibronix,
    Inc.

Registration
Statement on Form S-3

Filed
on September 12, 2023

File No.  333-274482 (the “Registration Statement”)

Request
for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under
the Securities Act of 1933, as amended, NanoVibronix, Inc. (the “Company”) hereby respectfully requests acceleration
of the effective date of the Registration Statement, so that it may become effective at 10:00 a.m., Eastern Time, on September
21, 2023, or as soon thereafter as practicable.

Should
any member of the staff of the Commission have any questions or comments with respect to this request, please contact our counsel, Haynes
and Boone, LLP, attention: Jayun Koo, Esq. at (212) 835-4823.

    Very truly yours,

    NANOVIBRONIX, INC.

    By:
    /s/ Brian
    Murphy

    Brian Murphy

    Chief Executive Officer

  cc:
  Jayun Koo, Esq., Haynes and Boone, LLP

United States securities and exchange commission logo
September 19, 2023
Brian Murphy
Chief Executive Officer
NanoVibronix, Inc.
525 Executive Blvd
Elmsford, New York 10523
Re:NanoVibronix, Inc.
Registration Statement on Form S-3
Filed September 12, 2023
File No. 333-274482
Dear Brian Murphy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Nicholas O'Leary at 202-551-4451 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Jayun Koo, Esq.

CORRESP
1
filename1.htm

NanoVibronix,
Inc.

525
Executive Boulevard

Elmsford,
New York 10523

August
9, 2023

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Industrial Applications and Services

Securities
and Exchange Commission

Washington,
D.C. 20549

Attention:
Abby Adams

    Re:
    NanoVibronix,
    Inc.

    Registration
    Statement on Form S-3

    Filed
    on August 1, 2023

    File
    No. 333-273574 (the “Registration Statement”)

Request
for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under
the Securities Act of 1933, as amended, NanoVibronix, Inc. (the “Company”) hereby respectfully requests acceleration
of the effective date of the Registration Statement, so that it may become effective at 4:30 p.m., Eastern Time, on August 11, 2023,
or as soon thereafter as practicable.

Should
any member of the staff of the Commission have any questions or comments with respect to this request, please contact our counsel, Haynes
and Boone, LLP, attention: Jayun Koo, Esq. at (212) 835-4823.

    Very
    truly yours,

    NANOVIBRONIX,
    INC.

    By:
    /s/
    Brian Murphy

    Brian
    Murphy

    Chief
    Executive Officer

    cc:
    Jayun
    Koo, Esq., Haynes and Boone, LLP

United States securities and exchange commission logo
August 8, 2023
Stephen Brown
Chief Financial Officer
NanoVibronix, Inc.
525 Executive Boulevard
Elmsford, NY 10523
Re:NanoVibronix, Inc.
Registration Statement on Form S-3
Filed August 1, 2023
File No. 333-273574
Dear Stephen Brown:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Abby Adams at (202) 551-6902 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Jayun Koo, Esq.

CORRESP
1
filename1.htm

NanoVibronix,
Inc.

525
Executive Boulevard

Elmsford,
New York 10523

December
14, 2020

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Securities
and Exchange Commission

Washington,
D.C. 20549

Attention:
Jason L. Drory

    Re:

    NanoVibronix,
    Inc.

    Registration
    Statement on Form S-3

    Filed
    on December 10, 2020

    File
    No. 333-251264 (the “Registration Statement”)

    Request
    for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”)
under the Securities Act of 1933, as amended, NanoVibronix, Inc. (the “Company”) hereby respectfully
requests acceleration of the effective date of the Registration Statement so that it may become effective at 5:00 p.m., Eastern
Time, on December 15, 2020, or as soon thereafter as practicable.

Should
any member of the staff of the Commission have
any questions or comments with respect to this request, please contact our counsel, Haynes and Boone, LLP, attention: Rick A.
Werner, Esq. at (212) 659-4974.

    Very
    truly yours,

    NANOVIBRONIX,
    INC.

    By:
    /s/
    Brian Murphy

    Brian
Murphy

    Chief
    Executive Officer

    cc:
    Rick
A. Werner, Esq., Haynes and Boone, LLP

United States securities and exchange commission logo
December 14, 2020
Brian Murphy
Chief Executive Officer
NanoVibronix, Inc.
525 Executive Blvd.
Elmsford, NY 10523
Re:NanoVibronix, Inc.
Registration Statement on Form S-3
Filed December 10, 2020
File No. 333-251264
Dear Mr. Murphy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jason L. Drory at 202-551-8342 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Rick Werner, Esq.

CORRESP
1
filename1.htm

NanoVibronix,
Inc.

525
Executive Boulevard

Elmsford,
New York 10523

August
10, 2020

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Securities
and Exchange Commission

Washington,
D.C. 20549

Attention:
Courtney Lindsay

    Re:

    NanoVibronix,
    Inc.

    Registration
    Statement on Form S-3

    Filed
    on July 21, 2020

    File
    No. 333-239965 (the “Registration Statement”)

    Request
    for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Rules and Regulations of the Securities and Exchange Commission (the “Commission”)
under the Securities Act of 1933, as amended, NanoVibronix, Inc. (the “Company”) hereby respectfully
requests acceleration of the effective date of the Registration Statement so that it may become effective at 5:00 p.m., Eastern
Time, on August 11, 2020, or as soon thereafter as practicable.

Should
any member of the staff of the Commission have any questions or comments with respect to this request, please contact our counsel,
Haynes and Boone, LLP, attention: Rick A. Werner, Esq. at (212) 659-4974.

    Very
    truly yours,

    NANOVIBRONIX,
    INC.

    By:

    /s/
    Brian Murphy

    Brian
    Murphy

    Chief
    Executive Officer

    cc:
    Rick A. Werner, Esq., Haynes and Boone, LLP

United States securities and exchange commission logo
July 28, 2020
Brian Murphy
Chief Executive Officer
NanoVibronix, Inc.
525 Executive Boulevard
Elmsford, New York 10523
Re:NanoVibronix, Inc.
Registration Statement on Form S-3
Filed July 21, 2020
File No. 333-239965
Dear Mr. Murphy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Courtney Lindsay at (202) 551-7237 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

January 27, 2020
Brian Murphy
Chief Executive Officer
NanoVibronix, Inc.
525 Executive Blvd.
Elmsford, New York
Re:NanoVibronix, Inc.
Registration Statement on Form S-3
Filed January 22, 2020
File No. 333-236000
Dear Mr. Murphy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Chris Edwards at (202) 551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Jayun Koo, Esq.

CORRESP
1
filename1.htm

NanoVibronix, Inc.

525 Executive Blvd.

Elmsford, NY 10523

January 27, 2020

By EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549

Attention: Chris Edwards

    RE:
    NanoVibronix, Inc.

Registration Statement on Form S-3

Filed January 22, 2020 (the “Registration Statement”)

Request for Acceleration

    File No. 333-236000

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, NanoVibronix, Inc. (the “Company”) hereby respectfully requests
acceleration of the effective date of the Registration Statement so that it may become effective at 5:00 p.m., Eastern Time, on
January 29, 2020, or as soon thereafter as practicable.

Should any member of the
staff of the U.S. Securities and Exchange Commission have any questions or comments with respect to this request, please contact
our counsel, Haynes and Boone, LLP, attention: Jayun Koo, Esq. at (212) 835-4823.

                    Very truly yours,

    NanoVibronix, Inc.

    By:
    /s/ Brian Murphy

    Brian Murphy

Chief Executive Officer

 cc: Rick A. Werner, Esq., Haynes and Boone, LLP

CORRESP
1
filename1.htm

NanoVibronix,
Inc.

525 Executive Blvd.

Elmsford, New York 10523

(914) 233-3004

    May 21, 2019

Via
EDGAR Correspondence

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.W.

Washington,
D.C. 20549

Re:
  NanoVibronix, Inc.

Registration
Statement on Form S-3

Initially
Filed December 31, 2018

File
No. 333-229106

Ladies
and Gentlemen:

NanoVibronix,
Inc. (the “Company”) is enclosing herewith an acceleration request with respect to the above captioned registration
statement. In connection with such request, the Company hereby acknowledges that:

 ● should
                                         the Commission or the staff, acting pursuant to delegated authority, declare the registration
                                         statement effective, it does not foreclose the Commission from taking any action with
                                         respect to the registration statement;

 ● the
                                         action of the Commission or the staff, acting pursuant to delegated authority, in declaring
                                         the registration statement effective, does not relieve the Company from its full responsibility
                                         for the adequacy and accuracy of the disclosure in the registration statement; and

 ● 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.

    Very truly yours,

    NanoVibronix, Inc.

    By:
     /s/ Stephen Brown

     Name: Stephen Brown

    Title: Chief Financial Officer

cc: Brian
Murphy, Chief Executive Officer, NanoVibronix, Inc.

Aurora
Cassirer, Esq. Troutman Sanders, LLP

Joseph
Walsh, Esq., Troutman Sanders, LLP

NanoVibronix,
Inc.

525 Executive Blvd.

Elmsford, New York 10523

(914) 233-3004

    May 21, 2019

Via
EDGAR Correspondence

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.W.

Washington,
D.C. 20549

Re:
  NanoVibronix, Inc.

Registration
Statement on Form S-3

Initially
Filed December 31, 2018

File
No. 333-229106

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the Securities Act of 1933, as amended, the undersigned registrant under the above-referenced registration statement
hereby requests acceleration of the effective date of the registration statement to May 23, 2019, at 4:00 p.m., New York time,
or as soon as practicable thereafter. Please notify our outside counsel, Joseph Walsh, Esq., by phone at (212) 704-6030, by fax
at (212) 704-5919, or by email at joseph.walsh@troutman.com of the date and time that the registration statement has been
declared effective.

    Very truly yours,

    NanoVibronix, Inc.

    By:
     /s/ Stephen Brown

     Name: Stephen Brown

    Title: Chief Financial Officer

cc: Brian
Murphy, Chief Executive Officer, NanoVibronix, Inc.

Aurora
Cassirer, Esq. Troutman Sanders, LLP

Joseph
Walsh, Esq., Troutman Sanders, LLP

CORRESP
1
filename1.htm

NanoVibronix, Inc.

525 Executive Blvd.

Elmsford, NY 10523

February 14, 2019

By EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549

Attention: Eric Atallah

    RE:
    NanoVibronix, Inc.

Registration Statement on Form S-3

Filed December 31, 2018

Request for Acceleration

    File No. 333-229106

Ladies and Gentlemen:

Pursuant to Rule 461 of
the Rules and Regulations of the Securities and Exchange Commission (the “Commission”) under the Securities
Act of 1933, as amended, NanoVibronix, Inc. (the “Company”) hereby requests acceleration of the effective date
of the above-mentioned Registration Statement on Form S-3 (the “Registration Statement”) to 5:00 p.m., Eastern
Time on February 15, 2019, or as soon thereafter as practicable.

Should any member of the
staff of the U.S. Securities and Exchange Commission have any questions or comments with respect to this request, please contact
our counsel, Haynes and Boone, LLP, attention: Rick A. Werner, Esq. at (212) 659-4974.

    Very truly yours,

    NanoVibronix, Inc.

    By:
    /s/ Stephen Brown

    Stephen Brown

Chief Financial Officer

February 5, 2019
Stephen Brown
Chief Financial Officer
NanoVibronix, Inc.
525 Executive Blvd.
Elmsford, New York
Re:NanoVibronix, Inc.
Registration Statement on Form S-3
Filed December 31, 2018
File No. 333-229106
Dear Mr. Brown:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Eric Atallah at (202) 551-3663 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Rick Werner

CORRESP
1
filename1.htm

November
1, 2017

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    NanoVibronix, Inc.

    Registration Statement on Form S-1

    File No. 333-218871

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, the undersigned, as underwriter of the proposed offering, hereby joins
the request of NanoVibronix, Inc. that the effective date of the above-referenced Registration Statement on Form S-1 be declared
effective at 5:00 p.m. (Washington, D.C. time) on Wednesday, November 1, 2017, or as soon as practicable thereafter.

In
connection with the proposed offering of the Company’s securities, copies of the preliminary prospectuses dated October
31, 2017 were distributed to the following persons in the following approximate amounts:

    To Whom Distributed
    Number of Copies

    Institutions
    50

    Individuals
    1,892

    Total
    1,942

We
have complied and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Sincerely,

    Dawson James Securities, Inc.

    By:
    /s/ Thomas W. Hands

    Name:
    Thomas W. Hands

    Title:
    President

CORRESP
1
filename1.htm

NanoVibronix,
Inc.

9
Derech Hashalom Street

Nesher,
Israel 36651

October
31, 2017

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Securities and Exchange Commission

Washington, D.C. 20549

Attention:
Timothy Buchmiller

    Re:
    NanoVibronix, Inc.

    Registration Statement on Form S-1, originally filed on June 21, 2017

    File
No. 333- 218871, as amended (the “Registration Statement”)

    Request
for Acceleration

Ladies
and Gentlemen:

Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, NanoVibronix, Inc. (the “Company”)
hereby respectfully requests acceleration of the effective date of the Registration Statement so that it may become effective
at 5:00 p.m., Eastern Time, on November 1, 2017, or as soon thereafter as practicable.

    Very truly yours,

    NANOVIBRONIX, INC.

    By:
     /s/ Stephen Brown

    Stephen Brown

    Chief Financial Officer

cc:    Rick
A. Werner, Esq., Haynes and Boone, LLP

Mail Stop 3030
September 18 , 2017

Via E -mail
Stephen Brown
Chief  Financial Officer
NanoVibronix, Inc.
9 Derech Hashalom Street
Nesher, Israel 36651

Re: NanoVibronix, Inc.
 Form 10 -K for the Fiscal Year Ended December 31, 2016
 Filed March 31, 2017
File No. 001-36445

Dear Mr. Brown :

We have completed our review of your filing s.  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence of action by the staff .

Sincerely,

        /s/ Martin James

Martin James
Senior Assistant Chief Accountant
        Office of Electronics and Machinery

Mail Stop 3030
July 13, 2017

Via E -mail
Stephen Brown
Chief  Financial Officer
NanoVibronix, Inc.
9 Derech Hashalom Street
Nesher, Israel 36651

Re: NanoVibronix , Inc.
 Form 10 -K for the Fiscal Year Ended December 31 , 2016
 Filed March 31, 2017
 Form 10 -Q for the Quarterly Period Ended March 31, 2017
Filed May 15 , 2017
File No.  001-36445

Dear  Mr. Brown :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following 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 these comments within ten business days b y providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments , we may have additional comments.

Form 10 -K for the Year Ended December 31, 2016

Consolidated Financial Statements

Consolidated Statements of Comprehensive Loss, page F -5

1. Revise this statement and other applicable sections of future filin gs to use parentheses to
clearly show Operating loss, Loss before taxes on income, Net loss, and Total
comprehensive loss as negative amounts, similar to your presentation s of the net loss per
share amounts here and net loss in the statements of cash flows.

Stephen Brown
NanoVibronix, Inc.
July 13 , 2017
Page 2

 Exhibits 31.1 and 31.2 Certifications Pursuant to Rule 13 -a-14(a)

2. On page 48, you correctly include Management’s Report on Internal Control over
Financial Reporting as of December 31, 2016.  Please amend the filing to provide
currently dated certifications that ar e consistent with the language in Item 601(b)(31) of
Regulation S -K, including the required language pertaining to your the internal control
over financial reporting in the introduction to paragraph 4 and paragraph 4(b) in its
entirety. This comment also a pplies to your Form 10 -Q for the period ended March 31,
2017.

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 st aff.

You may contact Dennis Hult at (202) 551 -3618, or me at (202) 551 -3671with any
questions.

Sincerely,

        /s/ Martin James

Martin J ames
Senior Assistant Chief Accountant
        Office of Electronics and Machinery

Mail Stop 3030
June 23, 2017

Brian Murphy
Chief Executive Officer
NanoVibronix, Inc.
9 Derech Hashalom Street
Nesher, Israel 36651

Re: NanoVibronix, Inc.
 Registration Statement on Form S-1
 Filed  June 21, 2017
 File No.  333-218871

Dear Mr. Murphy :

Our preliminary review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Ac t of 1933, the rules and
regulations under that Act, and the requirements of the form.  The financial statements do not
comply with Rule 8 -08 of Regulation S -X.  We will not perform a detailed examination of the
registration statement and we will not issue  comments.

If you were to request acceleration of the effective date of the registration statement in its
present form, we would likely recommend that the Commission deny your request.

You may contact Tim Buchmiller  at (202) 551 -3635 with any questions.

Sincerely,

 /s/ Amanda Ravitz

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: Rick A. Werner, Esq.
 Haynes and Boone, LLP