SecProbe.io

CORRESP
1
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February 27, 2026

VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Modular Medical, Inc.

    Registration Statement on Form S-1 File No. 333-293842

Ladies and Gentlemen:

Pursuant to Rule 461 of the
General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, (“Securities
Act”), Maxim Group LLC (“Maxim”), as placement agent, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 9:00 AM, Washington D.C. time, on Tuesday, March 3, 2026, or as soon thereafter
as may be practicable.

Maxim affirms that it is aware
of its obligations under the Securities Act in connection with this offering.

    Very truly yours,

    Maxim Group LLC

    By:
    /s/ Ritesh M. Veera

    Name:
    Ritesh M. Veera

    Title:
    Co-Head of Investment Banking

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February 27, 2026

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn: Robert Augustin

    Re:
    Modular Medical, Inc.

    Registration Statement on Form S-1

    Filed February 27, 2026

    File No. 333-293842

    Acceleration Request

    Requested Date: Tuesday, March 3, 2026

    Requested Time: 9:00 A.M. Eastern Time

Dear Mr. Augustin:

In accordance with Rule 461 of the Securities
Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the
above-captioned Registration Statement be accelerated so that it will be declared effective at 9:00 a.m. Eastern Time on Tuesday, March
3, 2026, or as soon thereafter as possible.

Please contact our counsel, Steven Lipstein of
Lucosky Brookman LLP at (732) 395-4416 with any questions you may have regarding this request. In addition, the Company requests that
you kindly notify Mr. Lipstein by telephone when this request for acceleration has been granted.

    Very truly yours,

    MODULAR MEDICAL, INC.

    /s/ James E. Besser

    James E. Besser

    Chief Executive Officer

 cc: Steven Lipstein (Lucosky Brookman LLP)

February 9, 2026
James Besser
Chief Executive Officer
Modular Medical, Inc.
10740 Thornmint Road
San Diego, CA 92127
Re:Modular Medical, Inc.
Draft Registration Statement on Form S-1
Submitted January 23, 2026
CIK No. 0001074871
Dear James Besser:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement and non-public draft
submission on EDGAR at least two business days prior to the requested effective date and time.
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 Robert Augustin at 202-551-8483 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and Services
cc:Lawrence Metelitsa

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 Modular Medical, Inc.

 10740 Thornmint Road

 San Diego, California 92127

 May 19, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, N.E.

 Washington, DC 20549

 Re:
 Modular Medical, Inc.

 Registration Statement on Form S-3, File No. 333-287313

 REQUEST FOR ACCELERATION OF EFFECTIVENESS

 Requested Date: May 21, 2025

 Requested Time: 5:00 pm, Eastern Time

 Ladies and Gentlemen:

 Modular Medical, Inc. (the "Company")
hereby requests that the effective date of the Company's Registration Statement on Form S-3 (File No. 333-287313), be accelerated
pursuant to Rule 461 under the Securities Act of 1933, as amended, so that it is declared and becomes effective at 5:00 p.m. Eastern Time
on May 21, 2025, or as soon thereafter as possible.

 Please contact our counsel, Lawrence Metelitsa
of Lucosky Brookman LLP at (732) 395-4405 with any questions you may have regarding this request. In addition, the Company requests that
you kindly notify Mr. Metelitsa by telephone when this request for acceleration has been granted.

 Sincerely yours,

 Modular Medical, Inc.

 /s/ James Besser

 James Besser

 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 19, 2025

James E. Besser
Chief Executive Officer
Modular Medical, Inc.
10740 Thornmint Road
San Diego, California 92127

 Re: Modular Medical, Inc.
 Registration Statement on Form S-3
 Filed May 15, 2025
 File No. 333-287313
Dear James E. Besser:

 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 Conlon Danberg at 202-551-4466 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Lawrence Metelitsa, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Modular Medical, Inc.

 10740 Thornmint Road

 San Diego, California 92127

 May 1, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, N.E.

 Washington, DC 20549

 Re:
 Modular Medical, Inc.

 Registration Statement on Form S-3, File No. 333-286768

 REQUEST FOR ACCELERATION OF EFFECTIVENESS

 Requested Date: 	May 5, 2025

 Requested Time: 	5:30 pm, Eastern Time

 Ladies and Gentlemen:

 Modular Medical, Inc. (the "Company")
hereby requests that the effective date of the Company's Registration Statement on Form S-3 (File No. 333-286768), be accelerated
pursuant to Rule 461 under the Securities Act of 1933, as amended, so that it is declared and becomes effective at 5:30 p.m. Eastern Time
on May 5, 2025, or as soon thereafter as possible.

 Please contact our counsel, Lawrence Metelitsa
of Lucosky Brookman LLP at (732) 395-4405 with any questions you may have regarding this request. In addition, the Company requests that
you kindly notify Mr. Metelitsa by telephone when this request for acceleration has been granted.

 Sincerely yours,

 Modular Medical, Inc.

 /s/ James Besser

 James Besser

 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 29, 2025

James E. Besser
Chief Executive Officer
Modular Medical, Inc.
10740 Thornmint Road
San Diego, CA 92127

 Re: Modular Medical, Inc.
 Registration Statement on Form S-3
 Filed April 25, 2025
 File No. 333-286768
Dear James E. Besser:

 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 Margaret Sawicki at 202-551-7153 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Lawrence Metelitsa, Esq.
</TEXT>
</DOCUMENT>

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May 12, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Modular Medical, Inc.

Registration Statement on Form S-1

File No. No. 333-271413

Acceleration Request

    Requested Date:
    May 15, 2023

    Requested Time:
    5:00 p.m. Eastern Time (US)

Ladies and Gentlemen:

In connection with the above-referenced Registration
Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as underwriter, hereby join
in the request of Modular Medical, Inc. that the effective date of the Registration Statement be accelerated so that it will be declared
effective at 5:00 p.m., Eastern Time (US), on May 15, 2023, or at such later time as the Company or its outside counsel, Lucosky Brookman
LLP, may request via a telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.

Pursuant to Rule 460 under the Act, we wish to
advise you that we have distributed approximately 450 copies of the Preliminary Prospectus dated May 12, 2023 through the date hereof,
to underwriters, dealers, institutions and others.

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

    Very truly yours,

    NEWBRIDGE SECURITIES CORPORATION

    By:
    /s/ Chad D. Champion

    Name:
    Chad D. Champion

    Title:
    Senior Managing Director

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Modular Medical, Inc.

16772 W. Bernardo Drive

San Diego, California 92127

May 12, 2023

VIA EDGAR

U.S. Securities & Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Modular Medical, Inc.

    Registration Statement on Form S-1

    File No. 333-271413

Ladies and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended,
Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration
Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Monday, May 15,
2023, or as soon thereafter as possible, or at such other time as the Company or its outside counsel, Lucosky Brookman LLP, may request
via a telephone call to the staff of the U.S. Securities & Exchange Commission..

* * * *

Very Truly Yours,

    Modular Medical, Inc.

    /s/ James E. Besser

    James E. Besser

    Chief Executive Officer

United States securities and exchange commission logo
May 1, 2023
James E. Besser
Chief Executive Officer
Modular Medical, Inc.
10740 Thornmint Drive
San Diego, California 92127
Re:Modular Medical, Inc.
Registration Statement on Form S-1
Filed April 24, 2023
File No. 333-271413
Dear James E. Besser:
            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 Conlon Danberg at 202-551-4466 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Lawrence Metelitsa, Esq.

CORRESP
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    July 6, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-265444

  Request
                                            for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Thursday, July 7, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ James E. Besser

    James E. Besser

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

United States securities and exchange commission logo
June 8, 2022
James Besser
Chief Executive Officer
Modular Medical, Inc.
16772 W. Bernardo Drive
San Diego, California 92127
Re:Modular Medical, Inc.
Registration Statement on Form S-1
Filed June 6, 2022
File No. 333-265444
Dear Mr. Besser:
            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 Dillon Hagius at 202-551-7967 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence Metelitsa

CORRESP
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    April 18, 2022

VIA EDGAR

U.S. Securities
and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-3

  Registration
                                            No. 333-264193

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Tuesday, April 19, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ James E. Besser

    James E. Besser

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

United States securities and exchange commission logo
April 14, 2022
James E. Besser
Chief Executive Officer
Modular Medical, Inc.
16772 W. Bernardo Drive
San Diego, California 92127
Re:Modular Medical, Inc.
Registration Statement on Form S-3
Filed April 8, 2022
File No. 333-264193
Dear Mr. Besser:
            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 Dillon Hagius at 202-551-7967 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence Metelitsa, Esq.

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OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    February 8, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as the representative of the several underwriters (the “Representative”), hereby joins in the request of Modular Medical, Inc. that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time, on Wednesday, February 9, 2022, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned, as the representative of the several underwriters, represents that the several underwriters have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
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    February 8, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Wednesday, February 9, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
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OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    February 4, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our request for acceleration of the effective date of the above-referenced Registration Statement. Modular Medical, Inc. is no longer requesting that such Registration Statement be declared effective at this time, and we hereby formally withdraw our request for acceleration of the effective date.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

    February 4, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 28, 2022, in which we requested the acceleration of the effective date of the above-referenced Registration Statement for Monday, January 31, 2022 at 5:00 p.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
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OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 28, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as the representative of the several underwriters (the “Representative”), hereby joins in the request of Modular Medical, Inc. that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time, on Monday, January 31, 2022, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned, as the representative of the several underwriters, represents that the several underwriters have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

    January 28, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Monday, January 31, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
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OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 27, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 26, 2022, in which we, as representative of the several underwriters of Modular Medical, Inc.’s proposed public offering of common stock, joined Modular Medical, Inc.’s request for acceleration of the effective date of the above-referenced Registration Statement for Thursday, January 27, 2022, at 5:00 p.m. Eastern Time. Modular Medical, Inc. is no longer requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

    January 27, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 26, 2022, in which we requested the acceleration of the effective date of the above-referenced Registration Statement for Thursday, January 27, 2022 at 5:00 p.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
filename1.htm

    January 26, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 21, 2022, in which we requested the acceleration of the effective date of the above-referenced Registration Statement for Tuesday, January 25, 2022 at 5:00 p.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this time, and we hereby formally withdraw our request for acceleration of the effective date.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
filename1.htm

    January 26, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Thursday, January 27, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
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OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 26, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as the representative of the several underwriters (the “Representative”), hereby joins in the request of Modular Medical, Inc. that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time, on Thursday, January 27, 2022, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned, as the representative of the several underwriters, represents that the several underwriters have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
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OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 26, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 21, 2022, in which we, as representative of the several underwriters of Modular Medical, Inc.’s proposed public offering of common stock, joined Modular Medical, Inc.’s request for acceleration of the effective date of the above-referenced Registration Statement for Tuesday, January 25, 2022, at 5:00 p.m. Eastern Time. Modular Medical, Inc. is no longer requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

    January 21, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Tuesday, January 25, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
filename1.htm

OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 21, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as the representative of the several underwriters (the “Representative”), hereby joins in the request of Modular Medical, Inc. that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time, on Tuesday, January 25, 2022, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned, as the representative of the several underwriters, represents that the several underwriters have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

    January 20, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 18, 2022, in which we requested the acceleration of the effective date of the above-referenced Registration Statement for Thursday, January 20, 2022 at 5:00 p.m. Eastern Time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting that such Registration Statement be declared effective at this time, and we hereby formally withdraw our request for acceleration of the effective date.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

CORRESP
1
filename1.htm

OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 20, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Withdrawal of Request
                                                                                                                                                                                       for Acceleration of Effectiveness

Ladies
and Gentlemen:

Reference is made to our letter, filed as correspondence via EDGAR on January 18, 2022, in which we, as representative of the several underwriters of Modular Medical, Inc.’s proposed public offering of common stock, joined Modular Medical, Inc.’s request for acceleration of the effective date of the above-referenced Registration Statement for Thursday, January 20, 2022, at 5:00 p.m. Eastern Time. Modular Medical, Inc. is no longer requesting that such Registration Statement be declared effective at this time, and we hereby formally withdraw our request for acceleration of the effective date.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

OPPENHEIMER & CO. INC.

85 Broad Street

New York, New York 10004

    January 18, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with the above-referenced Registration Statement, and pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Securities Act”), the undersigned, as the representative of the several underwriters (the “Representative”), hereby joins in the request of Modular Medical, Inc. that the effective date of the above-referenced Registration Statement be accelerated so that it will be declared effective at 5:00 p.m., Eastern Time, on Thursday, January 20, 2022, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned, as the representative of the several underwriters, represents that the several underwriters have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

    Very truly yours,

    OPPENHEIMER & CO. INC.

    As representative of the
several Underwriters

    OPPENHEIMER & CO. INC.

    By:
     /s/ Matthew Dormer

    Name:
    Matthew Dormer

    Title:
    Managing Director, Healthcare Investment Banking

CORRESP
1
filename1.htm

    January 18, 2022

VIA EDGAR

United State
Securities and Exchange Commission

Division of
Corporation Finance

100 F Street, NE

Washington,
D.C. 20549

 Re:      Modular
                                            Medical, Inc.

  Registration
                                            Statement on Form S-1

  Registration
                                            No. 333-260682

  Request
                                            for Acceleration of Effectiveness

Ladies
and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) hereby respectfully requests that the effective date of the above-captioned Registration Statement (the “Filing”) be accelerated so that it will be declared effective at 5:00 p.m. Eastern Time on Thursday, January 20, 2022, or as soon thereafter as possible.

* * * *

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Ellen O’Connor Vos

    Ellen O’Connor Vos

    Chief Executive Officer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

United States securities and exchange commission logo
November 8, 2021
Ellen O’Connor Vos
Chief Executive Officer
Modular Medical, Inc.
16772 W. Bernardo Drive
San Diego, CA 92127
Re:Modular Medical, Inc.
Registration Statement on Form S-1
Filed November 2, 2021
File No. 333-260682
Dear Ms. Vos:
            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 Jeffrey Gabor at 202-551-2544 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence Metelitsa, Esq.

CORRESP
1
filename1.htm

    July 12, 2021

VIA EDGAR

United States Securities and
Exchange Commission

100 F Street,
NE

Washington,
D.C. 20549

Attention: Mr. Jeffrey Gabor

 Re:      Modular Medical, Inc.

  Registration Statement on Form S-1

  Registration No.
                                                                                                                                             333-257752

  Request
                                         for Acceleration of Effectiveness

Ladies
and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Modular Medical, Inc. (the “Company”) respectfully requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement on Form S-1 so that it may become effective at 4:00 p.m., Eastern Time, July 14, 2021 or as soon thereafter as practicable or at such later time as the Company or its counsel may orally request via telephone call to the Staff of the Division of Corporate Finance of the Commission.

The Company would also appreciate telephone notice of such effectiveness to Lawrence G. Nusbaum of Gusrae Kaplan Nusbaum PLLC at (212) 269-1400 or if you have any other questions regarding this matter.

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Paul DiPerna

    Paul DiPerna

    Chairman, Chief Executive Officer,
 Chief Financial Officer, Secretary
and Treasurer

16772
West Bernardo Drive, San Diego, CA 92127 – 858.800.3500 – modular-medical.com

United States securities and exchange commission logo
July 9, 2021
Paul M. DiPerna
Chief Executive Officer
Modular Medical, Inc.
16772 W. Bernardo Drive
San Diego, CA 92127
Re:Modular Medical, Inc.
Registration Statement on Form S-1
Filed July 7, 2021
File No. 333-257752
Dear Mr. DiPerna:
            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 Jeffrey Gabor at 202-551-2544 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence G Nusbaum, Esq.

CORRESP
1
filename1.htm

    May 8, 2020

VIA EDGAR

United States Securities and
Exchange Commission

100 F Street,
N.E.

Washington,
D.C. 20549

Attention: Joseph McCann

 Re:      Modular Medical, Inc.

  Registration Statement on Form S-1

  Registration No.
                                                                                                                                             333-237615

  Request
                                         for Acceleration of Effectiveness

Ladies
and Gentlemen:

Modular
Medical, Inc. (the “Company”) respectfully requests, pursuant to Rule 461 under the Securities Act of 1933, as
amended (the “Act”), that the Securities and Exchange Commission (the “Commission”) accelerate the
effective date of the above-referenced Registration Statement so that it may become effective at 10:00 a m., Eastern Time, on Monday, May 11, 2020 or as soon thereafter as practicable or at such later time as the Company or its counsel may
orally request via telephone call to the Staff of the Division of Corporate Finance of the Commission. The Company would also
appreciate telephone notice of such effectiveness to Lawrence Nusbaum at (646) 662-9389 or Howard Mulligan at (917)
930-2172.

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Paul DiPerna

    Paul DiPerna

    Chairman, Chief Executive Officer,
 Chief Financial Officer, Secretary
and Treasurer

16772 W. Bernardo Drive, San Diego, CA 92127 - 858.800.3500 – modular-medical.com

April 24, 2020
Paul M. DiPerna
Chief Executive Officer, President and Chief Financial Officer
Modular Medical, Inc.
16772 W. Bernardo Drive
San Diego, CA 92127
Re:Modular Medical, Inc.
Registration Statement on Form S-1
Filed April 9, 2020
File No. 333-237615
Dear Mr. DiPerna:
            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 Joseph McCann at 202-551-6262 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
1
filename1.htm

    October 21, 2019

VIA EDGAR

United States Securities and
Exchange Commission

100 F Street,
N.E.

Washington,
D.C. 20549

Attention: Thomas Jones

 Re:      Modular Medical, Inc.

  Registration Statement on Form S-1

  Registration No.
                                                                                                                                             333-232377

  Request
                                         for Acceleration of Effectiveness

Ladies
and Gentlemen:

Modular Medical, Inc. (the “Company”) respectfully requests, pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement so that it may become effective at 4:00 p.m., Eastern Standard Time, October 22, 2019 or as soon thereafter as practicable or at such later time as the Company or its counsel may orally request via telephone call to the Staff of the Division of Corporate Finance of the Commission.  The Company would also appreciate telephone notice of such effectiveness to Lawrence Nusbaum or Howard Mulligan at (212) 269-1400.

    Very truly yours,

    MODULAR MEDICAL, INC.

    By:
     /s/ Paul DiPerna

    Paul DiPerna

    Chairman, Chief Executive Officer,
 Chief Financial Officer, Secretary
and Treasurer

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

October 21, 2019
Paul DiPerna
Chief Executive Officer
Modular Medical, Inc.
800 West Valley Parkway, Suite 203
Escondido, CA 92025
Re:Modular Medical, Inc.
Form 10-K for the Fiscal Year Ended March 31, 2019
Filed June 27, 2019
File No. 000-49671
Dear Mr. DiPerna:
            We have completed our review of your filings.  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.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence G. Nusbaum, Esq.

CORRESP
1
filename1.htm

    October 18, 2019

VIA EDGAR

Securities and
Exchange Commission

Division of
Corporation Finance

100 F Street,
N.E.

Washington,
D.C. 20549

Attn: Thomas Jones

 Re:      Modular Medical, Inc.

  Amendment
                                         No.2 to Registration Statement on Form S-1

  Filed
                                         on October 8, 2019

  File
                                         No. 333-232377

Dear
Mr. Jones:

Modular
Medical, Inc. (the “Company”) hereby submits this letter in response to comments from the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in its letter dated October 17, 2019
(the “Comment Letter”) relating to the above-referenced Amendment No.2 to Registration Statement on Form S-1
dated October 8, 2019 (the “Registration Statement”).

Set
forth below in bold are the Staff’s comments from the Comment Letter. For your convenience, each of the numbered paragraphs
below corresponds to the numbered comment in the Comment Letter and includes the caption used in the Comment Letter. Immediately
following each comment is the Company’s response to that comment. Defined terms used but not otherwise defined herein have
the meanings ascribed to such terms in the Registration Statement.

Pre-Commercialization
Steps, page 3

 1. We
                                         note your disclosure that you expect that the pre-submission conference with the FDA
                                         will be conducted near the end of the third quarter of 2019. Please update your disclosure
                                         and include any material reasons for any delay.

To
comply with the Staff’s request, the Company has revised the above noted disclosure referenced by the Staff in the “Prospectus
Summary – Pre-Commercialization Steps” and in the “Business – Governmental Regulations” sections
of the prospectus to read as follows:

“We
currently expect that such conference will be conducted during the fourth quarter of 2019.”

The Company has tentatively scheduled a pre-submission conference with Courtney Lias, Director, Division of
Chemistry and Toxicology Devices of the FDA, for November 15, 2019. The Company, however, respectfully submits to the Staff that,
because such conference date is tentative and not final, the Company, to ensure compliance with its disclosure obligations, has
not disclosed in the prospectus the tentative scheduled date of the conference. Rather, the Company has disclosed on pages 3 and
32 that it currently believes such conference will occur in the fourth quarter of 2019. The Company hereby informs the Staff that
the reason that its pre-submission conference with the FDA did not occur in the third quarter of 2019 was that the Company wanted
to continue working on its 510(k) application to make sure it narrowed down any issues and questions that it would want to discuss
with the FDA at the pre-submission conference in order to optimize its time with the FDA. The Company further informs the Staff
that no material event or circumstance has occurred or has become known to the Company that caused the Company to delay its conference
date. Additionally, the Company does not believe that the change in the timing of such conference will change the timing of the
Company’s 510(k) submission to the FDA.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

Government
Regulations, page 32

 2. We
                                         note your response to prior comment 2; however, where you attribute statements in your
                                         prospectus to your consultants as you do here and on page 2, the consultants’ consent
                                         should be filed as an exhibit to your registration statement.

As
indicated in response 2 of the Company’s October 8, 2019 response letter to the Staff, the Company does not believe any
of its consultants are “experts” as that term is defined in Section 7 of the Securities Act, which would require their
consents to be filed as exhibits to the Registration Statement pursuant to Rule 436 of the Securities Act. However, the Company
understands and acknowledges the Staff’s comment 2 in its Comment Letter and, in response thereto, the Company has removed
statements in the prospectus attributable to the Company’s consultants (including Susan Finneran and Kirk Brote) to avoid
giving a reader the impression that such statements are attributable to an “expert.”

Please
contact either me or our outside counsel copied hereon, Lawrence Nusbaum and Howard Mulligan of Gusrae Kaplan Nusbaum PLLC, at
212-269-1400, with any questions that you may have.

The
Company hereby respectfully submits this letter as of the date first above written.

    Very truly yours,

    /s/ Paul DiPerna

    Paul DiPerna

    Chairman, Chief Executive Officer,

Chief Financial Officer, Secretary and Treasurer

    CC:     Lawrence G. Nusbaum, Esq.

               Howard F. Mulligan, Esq.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

October 17, 2019
Paul DiPerna
Chief Executive Officer
Modular Medical, Inc.
800 West Valley Parkway, Suite 203
Escondido, California 92025
Re:Modular Medical, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed October 8, 2019
File No. 333-232377
Dear Mr. DiPerna:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our September 26, 2019 letter.
Form S-1 amended October 8, 2019
Pre-Commercialization Steps, page 3
1.We note your disclosure that you expect that the pre-submission conference with the FDA
will be conducted near the end of the third quarter of 2019.  Please update your disclosure,
and include any material reasons for any delay.
Government Regulations, page 32
2.We note your response to prior comment 2; however, where you attribute statements in
your prospectus to your consultants as you do here and on page 2, the consultants' consent
should be filed as an exhibit to your registration statement.

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 October 17, 2019 Page 2
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
October 17, 2019
Page 2
            You may contact Gary Newberry at 202-551-3761 or Lynn Dicker, Senior Accountant, at
202-551-3616 if you have questions regarding comments on the financial statements and related
matters.  Please contact Thomas Jones at 202-551-3601 or Russell Mancuso, Branch Chief, at
202-551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Lawrence G. Nusbaum, Esq.

CORRESP
1
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    October 8, 2019

VIA EDGAR

Securities and
Exchange Commission

Division of
Corporation Finance

100 F Street,
N.E.

Washington,
D.C. 20549

Attn: Gary Newberry

 Re:       Modular Medical, Inc.

   Form 10-K for the Fiscal
Year Ended March 31, 2019, Filed June 27, 2019

Amendment No. 1 to Form 10-Q for the Quarterly Period Ended June 30, 	2019,

Filed August 21, 2019

  File
                                         No. 000-49671

Dear
Mr. Newberry:

Modular
Medical, Inc. (the “Company”) hereby submits this letter in response to comments from the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in its letter dated September 13, 2019
(the “Comment Letter”) relating to the above-referenced filings (collectively, the “Filings”).

Set
forth below in bold are the Staff’s comments from the Comment Letter. For your convenience, each of the numbered paragraphs
below corresponds to the numbered comment in the Comment Letter and includes the caption used in the Comment Letter. Immediately
following each comment is the Company’s response to that comment. Defined terms used but not otherwise defined herein have
the meanings ascribed to such terms in the Filings.

Amendment
No. 1 to Form 10-Q for Quarterly Period Ended June 30, 2019

Note
1 – Organization and Summary of Significant Accounting Policies Earning Per Share (“EPS”), page 9

 1. We
                                         note that you do not quantify the amount of securities that could potentially dilute
                                         basic EPS in the future as required by ASC 260-10-50-1(c). Please revise future filings
                                         to include this information.

In response to the Staff’s
comment, the Company has added the required disclosure to quantify the amount of securities that could potentially dilute basic
EPS in the future as required by ASC 260-10-50-1(c). Currently, the only potentially dilutive securities are stock options granted
to the Company’s employees, directors and consultants. The Company will also include this disclosure in the financial statements
in future filings. Set forth below is the disclosure that the Company will include in the amended 10-Q for the three month period
ended June 30, 2019:

“For
the three months ended June 30, 2019, the Company excluded 1,552,594 options to purchase common stock from the computation of
diluted loss per share, as their inclusion would be anti-dilutive.”

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

Item
4. Controls and Procedures, page 15

 2. We
                                         note the disclosures presented in this section relating to management’s assessment
                                         of the effectiveness of your internal control over financial reporting (ICFR) at March
                                         31, 2019 and management’s conclusion that your ICFR was not effective at that date.
                                         Please amend your Form 10-Q to provide the required disclosure regarding the conclusion
                                         of your principal executive and principal financial officers on the effectiveness of
                                         your disclosure controls and procedures as of the end of the period covered by the report
                                         (i.e., June 30, 2019), based on the evaluation of these controls and procedures required
                                         by Exchange Act Rules 13a-15 and 15d-15. Please note that the disclosures outlined in
                                         Item 307 of Regulation S-K and required by Item 4 of Form 10-Q are separate from the
                                         annual ICFR disclosures required by Item 308(a) of Regulation S-K.

We
acknowledge that the disclosures presented in Item 4 did not include the required disclosure regarding the conclusion of our principal
executive and principal financial officer on the effectiveness of our disclosure controls and procedures as of June 30, 2019,
based on the evaluation of these controls and procedures required by Exchange Act Rules 13a-15 and 15d-15. We will amend and re-file
our Form 10-Q for the quarterly period ended June 30, 2019. We will notify the Staff when we complete the re-filing. We will revise
Item 4 to include the disclosures set forth below:

“Disclosure
Controls and Procedures. Our management is responsible for establishing and maintaining adequate internal control over our
financial reporting. Because of inherent limitations, internal control over financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate
because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

    2

Under
the supervision and with the participation of our management, including our Chief Executive Officer, we conducted an evaluation
of the effectiveness of the design and operation of our disclosure controls and procedures, as defined in Rules 13a-15(e) and
15d-15(e) under the Securities Exchange Act of 1934. Based upon that evaluation, our management concluded that our Company’s disclosure
controls and procedures were not effective as of the end of the period covered by this report, as noted below in management’s
report on internal control over financial reporting.

Changes
in Internal Control over Financial Reporting. During the three months ended June 30, 2019, there was no change in our internal
control over financial reporting that has materially affected, or is reasonably likely to materially affect, our internal control
over financial reporting.”

Please
contact either me or our outside counsel copied hereon, Lawrence Nusbaum of Gusrae Kaplan Nusbaum PLLC, at 212-269-1400, with
any questions that you may have.

The
Company hereby respectfully submits this letter as of the date first above written.

    Very truly yours,

    /s/ Paul DiPerna

    Paul DiPerna

    Chairman, Chief Executive Officer,

 Chief Financial Officer, Secretary and Treasurer

CC:
Lawrence G. Nusbaum, Esq.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

    3

CORRESP
1
filename1.htm

    October 7, 2019

VIA EDGAR

Securities and
Exchange Commission

Division of
Corporation Finance

100 F Street,
N.E.

Washington,
D.C. 20549

Attn: Thomas Jones

 Re:     Modular
                                         Medical, Inc.

  Amendment
                                         No.1 to Registration Statement on Form S-1

  Filed
                                         on September 9, 2019

   File
                                         No. 333-232377

Dear
Mr. Jones:

Modular
Medical, Inc. (the “Company”) hereby submits this letter in response to comments from the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in its letter dated September 26, 2019
(the “Comment Letter”) relating to the above-referenced Amendment No.1 to Registration Statement on Form S-1
September 9, 2019 (the “Registration Statement”).

Set
forth below in bold are the Staff’s comments from the Comment Letter. For your convenience, each of the numbered paragraphs
below corresponds to the numbered comment in the Comment Letter and includes the caption used in the Comment Letter. Immediately
following each comment is the Company’s response to that comment. Defined terms used but not otherwise defined herein have
the meanings ascribed to such terms in the Registration Statement.

Cover
Page

 1. We
                                         note that you revised the disclosure on the prospectus cover page to disclose
                                         the fixed price at which the securities will be sold in this offering in response to
                                         prior comment 1. Please also make corresponding changes elsewhere in the prospectus,
                                         such as in the Plan of Distribution and Determination of Offering Price sections.

To
comply with the Staff’s request, the Company has added appropriate corresponding disclosure in the “Plan of Distribution”
and “Determination of Offering Price” sections of the prospectus. Please note such disclosure was previously made
to the Cover Page and in the “Risk Factor” section of the prospectus.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

Overview,
page 2

 2. We
                                         note your new disclosure in the penultimate paragraph on page 2 that the prospectus
                                         contains information from a study commissioned by you and conducted by your consultant.
                                         Please file as an exhibit the consent of the consultant.  Also file the consent
                                         of the consultant whose opinion you cite on page 32.

With
respect to the consents requested by the Staff, the Company respectfully submits that neither (i) Kirk Brote Consulting, Inc.
(f/k/a Kinetic Innovations, Inc.) (“Kirk Brote”), who as set forth in the prospectus was the third party provider
of the study referenced by the Staff, nor (ii) Susan Finneran (the “Company’s FDA Regulatory Consultant”),
are “experts” under Rule 436 (“Rule 436”) of the Securities Act of 1933, as amended (the “Securities
Act”). Rule 436 requires that a consent be filed if any portion of a report or opinion of an expert is quoted or summarized
as such in a registration statement. Section 7 of the Securities Act (“Section 7”), provides that an expert
is “any accountant, engineer, or appraiser, or any person whose profession gives authority to a statement made by him.”
The Company respectfully submits that Kirk Brote as the third party provider of the above study and the Company’s FDA Regulatory
Consultant are not among the class of persons subject to Section 7 and Rule 436 as “experts,” unless the Company expressly
identifies such providers as experts or the statements are purported to be made on the authority of such providers as “experts.”
Accordingly, the Company believes that Kirk Brote and the Company’s FDA Regulatory Consultant are not and should not be
considered “experts” within the meaning of the federal securities laws.

In
addition, the Company notes that the consent requirements of Rule 436 are directed at circumstances in which an issuer has engaged
a third party expert or counsel to prepare a valuation, opinion or other report specifically for use in connection with a registration
statement. Neither the study prepared by Kirk Brote quoted in the prospectus nor the view expressed by the Company’s Regulatory
Consultant as stated in the prospectus, was prepared/given in connection with the Registration Statement. As a result of the foregoing,
the Company respectfully submits that these third party providers are not experts for purposes of Rule 436, and thus, consents
of such parties are not required to be filed as exhibits.

The
Company notes that Ms. Finneran was retained in her individual capacity (and not as a principal of Regulatory Compliance Experts,
Inc.) pursuant to the Company’s standard consultant contract and that she did not render a written opinion. The “scope
of work” set forth in that contract relates specifically to preparing the submission for FDA clearance and such contract
does not identify Ms. Finneran as an engineer or other professional within the meaning of Rule 436. The Company has made the appropriate
clarifying revisions on pages 3 and 32 of the prospectus.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

Pre-commercialization
Steps, page 3

 3. We
                                         note the last deletion that you mention in your response to prior comment 12; however,
                                         if your proposed product requires modification for the reasons stated in the deleted
                                         disclosure, it is unclear why you do not mention those modifications in disclosure like
                                         on page 3.  Please revise or advise.

In
response to the Staff’s Comment No. 12, the Company revised the “Our Business” section of the prospectus contained
in Amendment No.1 to the Registration Statement to delete the following sentence:

“We
believe such prototype will need to be modified to provide the safety features required to meet today’s standards and manufacturing
considerations and to restrain costs.”

The
Company’s original expectation, reflected on page 29 of the Registration Statement (filed on June 27, 2019), that its product
would be subject to pre-market approval by the FDA (“PMA”) and would require modifications to meet safety standards,
was based on the fact that the Company was once considering constructing its product in such a way that insulin was to be inserted
in the pump’s cartridge. As the Company is no longer considering constructing its pump in that manner, the Company expects
to be subject to the more streamlined 510(k) process, which typically does not involve the clinical trials associated with PMA.
Generally, gaining 510(k) clearance turns on demonstrating that the subject product is “substantially equivalent,”
in terms of safety and effectiveness, to a previously cleared 510(k) device. As the Company expects to be subject to 510(k) clearance
and to demonstrate its insulin pump’s substantial equivalence to a previously cleared product, the Company does not anticipate
making further modifications to its pump with regard to safety features or manufacturing considerations. Consequently, the Company
believes that the above language is no longer appropriate.

The
Offering, page 5

 4. Please
                                         supplementally provide us with copies of all written communications, as defined in Rule
                                         405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
                                         present to potential investors in reliance on Section 5(d) of the Securities Act, whether
                                         or not they retain copies of the communications.

The
Company acknowledges the Staff’s comment and advises the Staff that, to date, neither the Company nor anyone authorized
on the Company’s behalf, has presented any written communications to potential investors in reliance on Section 5(d) of
the Securities Act.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

Risk
Factors, page 7

 5. We
                                         note your response to prior comment 8. If you are required to hold annual meeting and
                                         do not hold such meetings, please include appropriate risk factors.

In response
to the Staff’s comment, the Company has added the following to the “Risk Factors” section of the Registration
Statement:

“We
have not held regular annual meetings of stockholders in the past, and, if we are required by the Nevada District Court to hold
an annual meeting pursuant to Nevada Revised Statutes §78.345(1), it could result in the unanticipated expenditure of funds,
time and other Company resources. Section 2.09 of our Amended Bylaws provides that an annual meeting of stockholders shall
be held each year on a date and at a time designated by our board of directors. Section 78.345(1) of the Nevada Revised Statutes
provides that, if there is a failure to hold the annual meeting for a period of 18 months after the last election of directors,
stockholders owning at least 15% of the voting power of the outstanding common stock may apply to the Nevada district court to
order the election of directors. We have not held regular annual meetings of stockholders because approximately 78.52% of our
voting stock is owned by our largest stockholders, thereby making it easy to obtain written consent in lieu of a meeting when
necessary. In addition, Mr. DiPerna and Manchester, collectively, have the right to appoint 4 out of a maximum of 5 directors
that can serve on our board. Moreover, handling matters by written consent allows us to save on financial and administrative resources
required to prepare for and hold such annual meetings. To our knowledge, no stockholder or director has requested our management
to hold such an annual meeting and no stockholder or director has applied to the Nevada district court seeking an order directing
us to hold such annual meeting of stockholders. However, if one or more stockholders or directors were to apply to the Nevada
district court seeking such an order, and, if the Nevada district court were to order an annual meeting before we were prepared
to hold one, the preparation for an annual meeting of stockholders and the meeting itself could result in the unanticipated expenditure
of funds, time, and other Company resources.”

 6. Please
                                         expand your response to prior comment 9 to provide us your analysis of the significance
                                         of any risk that your officer might have conflicts due to fiduciary duties to multiple
                                         entities.  For example, would conflicts exist when evaluating a potential acquisition?

The
Company respectfully submits that Mr. DiPerna’s involvement with the three entities discussed in our response to Staff Comment
No. 9 does not involve any material or significant risk of conflicts due to fiduciary duties (of loyalty, care or otherwise) owed
to multiple companies. The Company’s position is based on the fact that the specific lines of businesses in which such entities
are engaged are substantially different from the lines of business in which the Company is engaged, their current level of activity
and the time which Mr. DiPerna devotes to such entities. First, although Cardiac had once pursued the development of a low cost
heart monitor, none of Cardiac, FCP or PFIP is engaged in the production or commercialization of a medical product similar to
the Company’s prototype insulin pump. Second, Mr. DiPerna is no longer CEO and is now just a board member of Cardiac, the
activities of FCP are nearly dormant given the suspension of his consulting activities and PFIP currently has no operations other
than managing patent applications (none of which have or intended to be owned/licensed or otherwise used by the Company) and is
expected to be wound down by the end of 2019. Third, in the aggregate, Mr. DiPerna devotes less than three hours per month to
the affairs of Cardiac, FCP and PFIP.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 – modular-medical.com

For
similar reasons, if Mr. DiPerna were evaluating a potential acquisition candidate for the Company or considering a purchase proposal
for the stock or substantially all the assets of the Company and/or contemplating any such or similar situation or transaction,
the Company believes that his limited involvement with Cardiac, FCP and PFIP and the lack of cross-over operations of such entities
and the Company would not cause a conflict. Moreover, because of the modest capitalization and waning activities of Cardiac, FCP
and PFIP, it is highly unlikely that any of them would ever seek to acquire another company and, even if one of them had such
an objective, because the specific lines of business in which such entities are engaged are substantially different from those
in which the Company is engaged, it is highly unlikely that the target would be an entity that the Company would be interested
in acquiring. Likewise, because of the declining activity and limited future duration of Cardiac, FCP and PFIP, it is a highly
remote possibility that any of such entities would be the subject of an acquisition proposal which could result in a conflict
on the part of Mr. DiPerna.

Operating
Expenses, page 37

 7. We
                                         note your response to prior comment 15.  Please tell us with specificity where
                                         you revised the disclosure to clarify the nature of the consulting services mentioned
                                         in the second sentence of this section.

In
response to the Staff’s request in Comment No.15, the Company had modified the “Management’s Discussion and
Analysis of Financial Condition and Results of Operations—Operating Expenses ” section of Amendment No.1 to the Registration
Statement to clarify the nature of the consulting services mentioned in that section and to clarify what was meant by “increasing
outside expenses.” This modified language appears, for the period ended June 30, 2019, in the third paragraph on page 36
and, for the fiscal year ended March 31, 2019, in the fourth to last full paragraph on page 37. The two paragraphs provide
as follows:

“For
the three months ended June 30, 2019, research and development expenses increased by 418.3% to $703,783 as compared with $135,789
for the quarter ended June 30, 2018. The increase in research and development expenses is primarily due to increased engineering
headcount and increasing outside expenses necessary to the design and development of our innovative insulin pump. By “increasing
outside expenses,” we mean that, as we continue to implement product design enhancements and progress along the path to
FDA clearance, these expenses will escalate.”

“During
the fiscal year ended March 31, 2019, research and development expenses increased by 466% to $1,882,345 as compared with $332,642
for the prior fiscal year. The increase in research and development expenses is primarily due to increased engineering headcount
and increasing outside expenses necessary to the design and development of our innovative insulin pump. By “increasing outside
expenses,” we mean that, as we continue to implement product design enhancements and progress along the path to FDA clearance,
these expenses will escalate.”

800
West Valley Parkway, Suite 203, Escondido, CA 9202

September 26, 2019
Paul DiPerna
Chief Executive Officer
Modular Medical, Inc.
800 West Valley Parkway, Suite 203
Escondido, California 92025
Re:Modular Medical, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed September 9, 2019
File No. 333-232377
Dear Mr. DiPerna:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our July 23, 2019 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed September 9, 2019
Cover Page
1.We note that you revised the disclosure on the prospectus cover page to disclose the fixed
price at which the securities will be sold in this offering in response to prior comment 1.
Please also make corresponding changes elsewhere in the prospectus, such as in the Plan
of Distribution and Determination of Offering Price sections.

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 September 26, 2019 Page 2
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
September 26, 2019
Page 2
Overview, page 2
2.We note your new disclosure in the penultimate paragraph on page 2 that the prospectus
contains information from a study commissioned by you and conducted by your
consultant.  Please file as an exhibit the consent of the consultant.  Also file the consent of
the consultant whose opinion you cite on page 32.
Pre-commercialization Steps, page 3
3.We note the last deletion that you mention in your response to prior comment 12;
however, if your proposed product requires modification for the reasons stated in the
deleted disclosure, it is unclear why you do not mention those modifications in disclosure
like on page 3.  Please revise or advise.
The Offering, page 5
4.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
Risk Factors, page 7
5.We note your response to prior comment 8. If you are required to hold annual meeting and
do not hold such meetings, please include appropriate risk factors.
6.Please expand your response to prior comment 9 to provide us your analysis of the
significance of any risk that your officer might have conflicts due to fiduciary duties to
multiple entities.  For example, would conflicts exist when evaluating a potential
acquisition?
Operating Expenses, page 37
7.We note your response to prior comment 15.  Please tell us with specificity where you
revised the disclosure to clarify the nature of the consulting services mentioned in the
second sentence of this section.
Executive Compensation, page 43
8.Please reconcile the information in footnote (2) to your summary compensation table with
the amount included in the Option Awards column of the table.  Ensure that the amount
included in the table is computed as required by Regulation S-K Item 402(n)(2)(vi).

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 September 26, 2019 Page 3
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
September 26, 2019
Page 3
Note 1 - Organization and Summary of Significant Accounting Policies
Earnings Per Share ("EPS"), page F-9
9.We note your response to prior comment 25.  The revision does not quantify the amount
of securities that could potentially dilute basic EPS in the future as required by ASC 260-
10-50-1(c).  Please revise to include this information.
Note 5 - Stockholders' Equity
2017 Equity Incentive Plan, page F-12
10.We note your revisions in response to prior comment 26 do not address all of the
disclosures required by ASC 718-10-50-2(c) through (e).  Please revise to provide this
information.  Refer to the example in ASC 718-10-55-136.
            You may contact Gary Newberry at 202-551-3761 or Lynn Dicker, Senior Accountant, at
202-551-3616 if you have questions regarding comments on the financial statements and related
matters.  Please contact Thomas Jones at 202-551-3602 or Russell Mancuso, Branch Chief, at
202-551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Lawrence G. Nusbaum, Esq.

September 13, 2019
Paul DiPerna
Chief Executive Officer
Modular Medical, Inc.
800 West Valley Parkway, Suite 203
Escondido, CA 92025
Re:Modular Medical, Inc.
Form 10-K for the Fiscal Year Ended March 31, 2019
Filed June 27, 2019
Amendment No. 1 to Form 10-Q for the Quarterly Period Ended June 30, 2019
Filed August 21, 2019
File No. 000-49671
Dear Mr. DiPerna:
            We have limited our review of your filings 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 by 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.
Amendment No. 1 to Form 10-Q for the Quarterly Period Ended June 30, 2019
Note 1 - Organization and Summary of Significant Accounting Policies
Earnings Per Share ("EPS"), page 9
1.We note that you do not quantify the amount of securities that could potentially dilute
basic EPS in the future as required by ASC 260-10-50-1(c).  Please revise future filings to
include this information.
Item 4. Controls and Procedures, page 15
2.We note the disclosures presented in this section relating to management’s assessment of
the effectiveness of your internal control over financial reporting (ICFR) at March 31,
2019 and management’s conclusion that your ICFR was not effective at that date.  Please
amend your Form 10-Q to provide the required disclosure regarding the conclusion of

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 September 13, 2019 Page 2
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
September 13, 2019
Page 2
your principal executive and principal financial officers on the effectiveness of your
disclosure controls and procedures as of the end of the period covered by the report (i.e.,
June 30, 2019), based on the evaluation of these controls and procedures required by
Exchange Act Rules 13a-15 and 15d-15.  Please note that the disclosures outlined in Item
307 of Regulation S-K and required by Item 4 of Form 10-Q are separate from the annual
ICFR disclosures required by Item 308(a) of Regulation S-K.
            In closing, 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.
            You may contact Gary Newberry at (202) 551-3761 or Lynn Dicker, Senior Accountant,
at (202) 551-3616 with any questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Lawrence G. Nusbaum, Esq.

CORRESP
1
filename1.htm

    September 9, 2019

VIA EDGAR

Securities and
Exchange Commission

Division of
Corporation Finance

100 F Street,
N.E.

Washington,
D.C. 20549

Attn: Thomas Jones

Re: Modular
                                         Medical, Inc.

 Registration
                                         Statement on Form S-1

 Filed
                                         on June 27, 2019

  File
                                         No. 333-232377

Dear
Mr. Jones:

Modular
Medical, Inc. (the “Company”) hereby submits this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in its letter dated July 23, 2019 (the
“Comment Letter”) relating to the above-referenced Registration Statement on Form S-1 (the “Registration
Statement”).

Set
forth below in bold are the Staff’s comments from the Comment Letter. For your convenience, each of the numbered paragraphs
below corresponds to the numbered comment in the Comment Letter and includes the caption used in the Comment Letter. Immediately
following each comment is the Company’s response to that comment. Defined terms used but not otherwise defined herein have
the meanings ascribed to such terms in the Registration Statement.

Cover
Page

 1. Please
                                         disclose the fixed price at which the securities will be sold in this offering. See Item
                                         501(b)(3) of Regulation S-K. Depending on your responses to the other comments in this
                                         letter, you may disclose, if true, that the selling shareholders will sell at the disclosed
                                         fixed price per share until your shares are quoted on the OTC Bulletin Board or in the
                                         OTCQX or OTCQB marketplace of OTC Link and thereafter at prevailing market prices or
                                         at privately negotiated prices.*
                                         Please
                                         also make corresponding changes elsewhere in the prospectus.

To
comply with the Staff’s comment, we have made the requested change on the Prospectus cover page and Plan of Distribution
section of the Prospectus and have added the following risk factor which incorporates such disclosure in the “Risk Factor”
section of the Prospectus.

*
As requested by the Staff the last 4 words of such sentence replaced
the words “in privately negotiated transactions”

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 - modular-medical.com

“Our shares
of common stock are quoted on the OTC Pink Open Market; and there currently is no active trading market for our shares.

Our
shares of common stock are traded on the OTC Pink Open Market. There is currently no active trading market and for at least the
prior 3 years there has been no active trading market for our common stock. There can be no assurance that an active trading market
for our common stock will ever develop or if one develops it will be sustained. Furthermore, because our shares of common stock
are traded on the OTC Pink Open Market, the Selling Shareholders will only offer and sell their shares at a fixed price of
$3.00 per share until our shares are quoted on the OTC Bulletin Board or in the OTCQX or OTCQB marketplace of the OTC Link, and
, thereafter, at prevailing market prices or previously negotiated prices.”

 2. Given
                                         the nature and size of the transaction being registered, advise the staff of the company’s
                                         basis for determining that the transaction is appropriately characterized as a transaction
                                         that is eligible to be made on a shelf basis under Rule 415(a)(1)(i).

The
Company acknowledges the Staff’s comment. We have considered the factors set forth in Securities Act Rule Compliance and
Disclosure Interpretations (“C&DI”) 612.09, regarding whether a purported secondary offering is really
a primary offering in which selling shareholders are acting as underwriters selling on behalf of an issuer as the basis for determining
that the transaction is appropriately characterized as a transaction that is eligible to be made on a shelf basis under Rule 415(a)(1)(i).
Based on the factors set forth in C&DI 612.09, the Company respectfully submits that the Selling Shareholders
(as defined below), are not acting as underwriters or otherwise as a conduit for the Company and that the resale
of the 9,658,201 shares of the Company’s common stock to be registered by the Registration Statement is not
an indirect primary offering being conducted by or on behalf of the Company. The Company respectfully submits that
the transaction set forth in the Registration Statement relates to the offering of securities solely by or on behalf of a person
other than the registrant, a subsidiary of the registrant or a person of which the registrant is a subsidiary, as discussed in
greater detail below, and therefore, is appropriately characterized as a transaction that is eligible to be made on a continuous
or delayed basis under Rule 415(a)(1)(i) promulgated under the Securities Act of 1933, as amended (the “Securities Act”).

 I. Background.

On
July 24, 2017, pursuant to a Common Stock Purchase Agreement, dated as of July 24, 2017, by and among, the purchasers named therein
and the Company (the “2017 SPA”), the Company sold to such purchasers in a private placement (the “2017
Placement”) an aggregate 7,801,213 shares of its common stock at a purchase price of $0.66 per share, resulting in gross
proceeds to the Company of $4,731,872. Between November 2018 and March 29, 2019, pursuant to a Common Stock Purchase Agreement,
dated as of November 19, 2018, by and among, the purchasers named therein and the Company (the “2018 SPA” and
together with the 2017 SPA, collectively, the “SPAs”), the Company sold to such purchasers in a private placement
(the “2018 Placement” and together with the 2017 Private Placement, collectively, the “Private Placements”)
an aggregate of 1,856,988 shares at a purchase price of $2.25 per share, resulting in gross proceeds to the Company of $4,142,666.
At each closing of the 2 Private Placements, the purchasers paid the full purchase price for their Shares.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 - modular-medical.com

Substantially
all of the 9,658,201 shares (each a “Share”), sold to purchasers (each a “Selling Shareholder”),
in the 2 Private Placements are included for resale in the Registration Statement. The Registration Statement was filed with the
Commission on June 27, 2019.

Section
2(a)(11) of the Securities Act defines an underwriter as “any person who has purchased from an issuer with a view to,
or offers or sells for an issuer in connection with, the distribution of any security, or participates or has a direct or indirect
participation in any such undertaking, or participates or has a participation in the direct or indirect underwriting of any such
undertaking.”  The definition’s phrase “with a view to … distribution” creates a subjective
standard regarding an investor’s intent.  As such, it is fact-specific.  In determining intent, courts and the Commission
often look to evidence based on objective criteria.

In
prior no-action letters, the Staff has noted that the determination of “underwriter” status depends on all of the
facts and circumstances surrounding a particular transaction.

The
Staff also has stated that institutional investors generally should not be deemed to be underwriters with regard to the acquisition
of large amounts of securities, provided such securities are acquired in the ordinary course of the investor’s business and that
the investor has no arrangement with any person to participate in the distribution of such securities.

 II. Staff Guidance

Rule
415(a)(1)(i) of the Securities Act provides that securities may be registered for an offering to be made on a continuous or delayed
basis in the future, provided that the registration statement pertains only to securities which are to be offered or sold solely
by or on behalf of a person or persons other than the registrant, a subsidiary of the registrant or a person of which the registrant
is a subsidiary. As stated in the Registration Statement, the Shares are being registered for resale or other disposition by each
of the Selling Shareholders only and no Shares or other securities are being registered for the Company. Proceeds from the sale
of any Share are solely for the account of the Selling Shareholders.

With
regard to the Staff’s comment, we note that C&DI 612.09 indicates that the issue of whether an offering is by or on
behalf of the issuer involves an analysis of facts beyond the entity that will receive the proceeds of the sale of securities
that are being registered. Specifically, C&DI 612.09 states that consideration should be given to the following factors:

 1. how
                                         long the selling shareholders have held the shares;

 2. the
                                         circumstances under which they have received them;

 3. their
                                         relationship to the issuer;

 4. the
                                         amount of shares involved;

 5. whether
                                         the selling shareholders are in the business of underwriting securities; and

 6. whether
                                         under all the circumstances it appears that the seller is acting as a conduit for the
                                         issuer.

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 - modular-medical.com

 III. Analysis

We
have analyzed the factors set forth in C&DI 612.09 and believe that this analysis provides confirmation that the resale of
the Shares being registered for the Selling Shareholders in the Registration Statement is appropriately characterized as a transaction
that is eligible to be made on a shelf basis under Rule 415(a)(1)(i). The following is a summary of our analysis of these factors.

              A.          	How
Long the Selling Shareholders Have Held the Shares. The longer the Shares have been held, the less likely it is that the
Selling Shareholders are acting as conduits (underwriters) for the Company and the more likely it is that the Selling Shareholders
acquired the Shares as long-term investors. All of the Selling Shareholders who purchased their respective Shares (7,801,213 in
the aggregate), in the 2017 Private Placement have held their Shares since July 24, 2017 (in excess of 2 years). All of the Selling
Shareholders who purchased their respective Shares (1,856,988 in the aggregate), in the 2018 Private Placement, have held their
Shares since November 19, 2018 (in excess of 8 months), except for 2 small Selling Shareholders, Solas Capital Partners II, LP
and William Meehan IRA, who purchased their 70,556 aggregate amount of Shares on approximately March 29, 2019. During the time
commencing on the July 24, 2017 closing date of the 2017 Placement through and including the date of this letter, to the Company’s
knowledge, no Selling Shareholder has sold or otherwise transferred any of its Shares.

In
addition, the Selling Shareholders acquired the Shares knowing that there was no active trading market for the Shares and that
they could not liquidate their Shares. In fact, for at least the 3 year period prior to the date of this letter, to the Company’s
knowledge, there has been no active trading market for the Shares and virtually no existing trading market in the Company’s
shares of common stock on the OTC Pink Open Market. In short, no Selling Shareholder could have any reasonable expectation that
the market could absorb even a small amount of Shares, let alone 9,658,201 Shares, which provides further evidence that none of
the Selling Shareholders intended to act and/or are acting as conduits (underwriters) for the Company.

Substantially
all of the Shares included in the Registration Statement have been held by the Selling Shareholders for approximately 2 years
or 8 months (as applicable). The Selling Shareholders held their Shares for 13 months or 3 months (as applicable) prior to the
filing of the Registration Statement. These lengthy holding periods are substantially longer than the periods required by the
Staff for valid “PIPE” (private-investment, public-equity) transactions.

In
a prior C&DI, the Staff codified its “PIPEs” interpretation (the “PIPEs Interpretation”)
by providing in relevant part that:

800
West Valley Parkway, Suite 203, Escondido, CA 92025 - 760.392.1343 - modular-medical.com

“In
a PIPE transaction (private-investment, public-equity), the staff will not object if a company registers the resale of securities
prior to their issuance if the company has completed a Section 4(2)-exempt sale of the securities (or in the case of
convertible securities, of the convertible security itself) to the investor, and the investor is at marketrisk at the time of
filing of the resale registration statement….The closing of the private placement of the unissued securities must occur
within a short time after the effectiveness of the resale registration statement.”

The
PIPEs Interpretation contemplates that a valid secondary offering could occur immediately following the closing of the placement.
Since no holding period is required for a PIPE transaction to be a valid secondary offering, by definition a holding period of
2 years or 8 months as indicated above should be sufficient for a valid secondary offering.

The
above lengthy holding periods and the non-liquid market for the Shares indicates that the Shares were not acquired by the Selling
Shareholders with a “view to distribution.” The Selling Shareholders have borne market risk associated with
owning the Shares since they purchased their Shares at a fixed price without the ability to influence the consummation of the
transaction or the purchase price per Share. It is our understanding that the Staff has become increasingly concerned with transactions
that include significant price adjustments and ratchet provisions, which was not the case here. This was a sale of common stock
only, whereas the transactions that have historically concerned the Staff have involved convertible securities containing price
adjustment mechanisms. These circumstances distinguish potential resales of Shares by the Selling Shareholders from a primary
offering by the Company or an underwriter acting on its behalf. Although it should be noted that in the SPA for the 2018 Placement,
the purchasers negotiated for a limited anti-dilution provision, such provision terminated by its terms prior to the filing of
the Registration Statement and no additional securities of the Company were issued to any Selling Shareholder or any other person
pursuant to such provision.

	             B.          	The
Circumstances Under Which the Selling Shareholders Received the Shares. All of the Selling Shareholders purchased their
Shares in a bona fide, arms-length private placement transactions pursuant to Section 4(a)(2) of the Securities Act and/or Rule
506 of Regulation D promulgated thereunder. The Selling Shareholders who purchased their Shares in the 2017 Placement received
no registration rights with respect to their Shares. With regard to the Selling Shareholders who purchased their Shares in the
2018 Placement, the Company agreed to use its commercially best efforts to file a registration statement with the SEC within 90
days after the final closing of the 2018 Placement, which date was June 29, 2019, two days after the date that the Company filed
the Registration Statement with the Commission. The registration rights were a condition sub

July 23, 2019
Paul DiPerna
Chief Executive Officer
Modular Medical, Inc.
800 West Valley Parkway, Suite 203
Escondido, California 92025
Re:Modular Medical, Inc.
Registration Statement on Form S-1
Filed June 27, 2019
File No. 333-232377
Dear Mr. DiPerna:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1 filed June 27, 2019
Cover Page
1.Please disclose the fixed price at which the securities will be sold in this offering.  See
Item 501(b)(3) of Regulation S-K.  Depending on your responses to the other comments in
this letter, you may disclose, if true, that the selling shareholders will sell at the disclosed
fixed price per share until your shares are quoted on the OTC Bulletin Board or in the
OTCQX or OTCQB marketplace of OTC Link and thereafter at prevailing market prices
or in privately negotiated transactions.  Please also make corresponding changes
elsewhere in the prospectus.
2.Given the nature and size of the transaction being registered, advise the staff of the
company's basis for determining that the transaction is appropriately characterized as a
transaction that is eligible to be made on a shelf basis under Rule 415(a)(1)(i).

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 July 23, 2019 Page 2
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
July 23, 2019
Page 2
Prospectus Summary, page 2
3.Please explain clearly each material step you must take to reach commercialization of
your technology to address the markets mentioned on page 26.  Include the material
hurdles before you are able to address these markets. If such detail is not appropriate for
your prospectus summary, carefully consider the information that is the most significant,
and briefly highlight that information in the summary and include more detailed
disclosure elsewhere in your prospectus.
The Company, page 2
4.Please expand the disclosure in the third paragraph of this section to disclose the
regulatory status of your insulin pump.  Also, tell us whether the "substantial feedback"
mentioned on page 2 has revealed any material disadvantages of your insulin pump.
The Private Placement Transactions, page 2
5.Please reconcile the number of shares purchased for cash in the 2017 placement as
disclosed here and on page F-10.  Also, if some of the selling shareholders did not pay
cash for the offered securities, please disclose the number of shares exchanged for new
shares and when the exchanged shares were "previously canceled"; include appropriate
disclosure regarding the exchange in your "Selling Shareholders" section regarding each
selling shareholder who did not pay cash.
Corporate History and Background, page 3
6.Please provide us your analysis of whether you are an "emerging growth company" as
defined in Section 2 of the Securities Act.
Risk Factors, page 4
7.Please include appropriate risk factors regarding (1) the conclusions of your CEO and
CFO related to the effectiveness of your controls and procedures and (2) the extent of your
board of directors' ability to adopt any recapitalization by effecting a forward or reverse
split of the outstanding shares of your common stock without shareholder approval. We
note your Article IX of exhibit 3.1.
8.We note your disclosure on page 23 regarding your Board of Directors being elected
annually.  Please show us how you comply with Regulation 14A or 14C, as appropriate, in
connection with shareholder action.  Also clarify whether shareholders have the ability to
vote on the directors appointed under the agreement mentioned on page 34.  Include any
appropriate risk factors.

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 July 23, 2019 Page 3
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
July 23, 2019
Page 3
Any failure to attract and retain skilled directors, executives, employees and consultants, page 7
9.We note your disclosure on page 33 that Mr. DiPerna is the manager of one entity and the
chief executive officer of another entity.  Please add a risk factor to highlight, if
appropriate, the amount of time Mr. DiPerna may work on your business and any
conflicts.  Also, please tell us why the disclosure on page 33 does not address the activity
mentioned at the end of schedule 1.1 of exhibit 10.4.
We will need to outsource and rely on third parties, page 7
10.Please expand the appropriate section to disclose the material termination provisions of
your agreements mentioned in the third sentence of the second paragraph of this risk
factor.  Also, provide us your analysis of whether you must file any of the agreements as
exhibits to your registration statement.
Selling Shareholders, page 16
11.We note your disclosure indicating that footnotes would contain any exceptions to your
statements in the last sentence of the first paragraph.  Please ensure that the footnotes that
you mention describe the exceptions.
Our Solution, page 27
12.Please disclose the basis, to the extent material, for your belief that your "proposed insulin
pump will be the simplest and least expensive product on the market and the easiest for
physicians to prescribe for diabetes patients" in view of the status of your product
mentioned in the fourth paragraph on page 27.  Also, if claims regarding safety can be
made only after the FDA has not cleared a product for sale, please tell us why you believe
it is appropriate to make claims regarding safety like you do on page 27.
Government Regulation, page 28
13.We note your disclosure regarding your intended consumers in the last sentence on page
27.  Please tell us why this section does not address the regulatory process of relevant
foreign authorities.
14.We note your disclosure that you anticipate that your proposed product will require the
PMA approval process.  Please more fully disclose the nature of that process; include, as
applicable, the investigational device exemption process, and, if needed, whether you have
received the exemption.  Also disclose the duration of the PMA process, and clarify the
nature of the "more rigorous examination" that you mention in the first sentence on page
29.

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 July 23, 2019 Page 4
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
July 23, 2019
Page 4
Operating Expenses, page 30
15.Please clarify the nature of the consulting services mentioned in the second sentence of
this section.  Also, clarify what you mean by the phrase "increasing outside expenses."
Management, page 33
16.If you elect to highlight achievements related to the companies that you mention, please
ensure that your disclosure is balanced.  For example, did the companies incur material
losses?
17.Please provide the disclosure required by Item 401(e)(1) of Regulation S-K regarding the
specific experience, qualifications, attributes, or skills that led to the conclusion that
Messrs. DiPerna, Burns and Frank should serve as directors.
Involvement in Legal Proceedings, page 34
18.We note the reference to the "disclosure with regard to Mr. Burns;" however, the
disclosure appears to be missing.  Please advise or revise.
The DiPerna Employment Agreement and Related Agreements, page 35
19.Please disclose the post-termination compensation provision mentioned in section 5(c) of
exhibit 10.4 and the change of control compensation mentioned in section 6 of that
exhibit.  Also, file as exhibits to your registration statement the agreements mentioned in
the last sentence of this section.
Composition of the Board, page 35
20.Please describe the effect of section 3.03 of exhibit 3.2 to your registration statement.
Executive Compensation, page 37
21.Please reconcile your disclosure in the table on page 38 about the salary of $30,000 and all
other compensation of $105,000 for the fiscal year ended March 31, 2018 with your
disclosure in footnote (1) on page 38 that Mr. Diperna was named CEO on July 24, 2017
at an annual salary base of $180,000.  Also, clarify how the option grant mentioned in the
first paragraph on page 39 is reflected in the first table on page 38, and note the disclosure
required by the Instructions to Regulation S-K Item 402(c)(2)(v) and (vi) or Item
402(n)(2)(v) and (n)(2)(vi), as appropriate.
Related Party Transactions, page 40
22.We note your reference to $120,000 in the first paragraph.  Please revise given the
threshold in Regulation S-K Item 404(d)(1).  Also, provide disclosure that addresses the
entire time period mentioned in Instruction 1 to Item 404.

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 July 23, 2019 Page 5
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
July 23, 2019
Page 5
Consolidated Statements of Stockholders’ Equity, page F-4
23.Please revise the penultimate caption of the table to correctly indicate that the net loss is
for the fiscal year ended March 31, 2019, rather than for the quarter ended March 31,
2019.
Note 1 - Organization and Summary of Significant Accounting Policies
Earnings Per Share ("EPS"), page F-9
24.Revise this note and your Consolidated Statement of Operations on page F-3 to present
your earnings per share to the nearest cent, so as not to imply more precision than exists.
25.Revise to disclose the securities that could potentially dilute basic EPS in the future that
were not included in the computation of diluted EPS because to do so would have been
anti-dilutive for the periods presented.  Refer to ASC 260-10-50-1(c).
Note 5 - Stockholders' Equity
Stock Options, page F-11
26.Please revise to disclose the method used to estimate the fair value of the equity
instruments granted during the period to both employees and consultants, as well as the
underlying basis for the assumptions used.  Refer to ASC 718-10-50-2(f) and 505-50-50-
1. In addition, as applicable, revise to provide the disclosures required by ASC 718-10-50-
2(c) through (e).
27.You disclose on page F-12  that options issued to consultants were valued at $682,240 and
was accrued monthly in research and development expenses for the year ended March 31,
2019.  However, we note from your statement of cash flows that total stock-based
compensation expense for fiscal year 2019 was $532,108.  Please revise to clarify this
discrepancy and to disclose the method used for measuring compensation cost from share-
based payment arrangements.
Signatures, page 48
28.Please clarify below the second paragraph of text that Form S-1 requires on the Signatures
page who signed your document in the capacity of principal accounting officer or
controller.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNamePaul DiPerna
 Comapany NameModular Medical, Inc.
 July 23, 2019 Page 6
 FirstName LastName
Paul DiPerna
Modular Medical, Inc.
July 23, 2019
Page 6
            You may contact Gary Newberry at 202-551-3761 or Lynn Dicker, Senior Accountant, at
202-551-3616 if you have questions regarding comments on the financial statements and related
matters.  Please contact Thomas Jones at 202-551-3602 or Russell Mancuso, Branch Chief, at
202-551-3617 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Electronics and Machinery
cc:       Lawrence G. Nusbaum, Esq.

CORRESP
1
filename1.htm

    Gusrae
    Kaplan & Nusbaum pllc

    ATTORNEYS AT LAW

    120 WALL STREET –
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    OF COUNSEL

    NEW YORK, NY 10005
    ROBERT L. BLESSEY

    SCOTT
                                         H. GOLDSTEIN

        MARTIN H. KAPLAN

        LAWRENCE G. NUSBAUM

        RYAN J. WHALEN

        BENJAMIN S. KAPLAN

    ____

        TEL
        (212) 269-1400

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                                                                    June 26, 2019

VIA EDGAR SUBMISSION

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

	Re:          	Registration Statement
on Form S-1 of Modular Medical, Inc.

Ladies and Gentlemen:

On
behalf of Modular Medical, Inc. (the “Company”), we are transmitting one copy of the above-referenced Registration
Statement on Form S-1 (the “Registration Statement”) of the Company for filing under the Securities Act of 1933, as
amended. The Company has previously sent by wire transfer funds in the amount of $3,511.73 to cover the registration fee.

Should
you have any questions or comments regarding this filing, please call either the undersigned or Howard Mulligan at (212) 269-1400.

    Sincerely,

    /s/ Lawrence G. Nusbaum

    Lawrence G. Nusbaum