SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 20, 2025

Joel Fruendt
Chief Executive Officer
SenesTech, Inc.
13430 North Dysart Road, Suite 105
Surprise, Arizona 85379

 Re: SenesTech, Inc.
 Registration Statement on Form S-3
 Filed August 15, 2025
 File No. 333-289650
Dear Joel Fruendt:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Jane Park at 202-551-7439 with any questions.

 Sincerely,

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

CORRESP
 1
 filename1.htm

 SenesTech,
Inc.
13430 North Dysart Road, Suite 105

 Surprise,
Arizona 85379

 August
20, 2025

 Via
EDGAR

 U.S.
Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, N.E.

 Washington,
DC 20549

 Attention:
Jane Park

 Re: SenesTech,
 Inc.
 Registration Statement on Form S-3
 File No. 333-289650

 Ladies
and Gentlemen:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended, SenesTech, Inc. (the " Company ") hereby requests
that the effective date of the above-captioned Registration Statement on Form S-3 (the " Registration Statement "),
be accelerated to 4:00 p.m., Eastern time, on Friday, August 22, 2025, or as soon as practicable thereafter. Once the Registration Statement
has been declared effective, please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck
at (602) 445-8349 or, in her absence, Brian H. Blaney at (602) 445-8322.

 The
Company acknowledges that (1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement
effective, it does not foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or
the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments
and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

 [signature
page follows]

 SIGNATURES

 Pursuant
to the requirements of the Securities Exchange Act of 1934, the Registrant has duly
caused this report to be signed on its behalf by the undersigned, hereunto duly
authorized.

 Very
truly yours,

 SENESTECH, INC.

 By:
 /s/ Thomas
C. Chesterman

 Name:
 Title:
 Thomas C. Chesterman Executive Vice President, Chief Financial
 Officer, Treasurer and Secretary

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 16, 2025

Joel L. Fruendt
President and Chief Executive Officer
SenesTech, Inc.
13430 North Dysart Road, Suite 105
Surprise, AZ 85379

 Re: SenesTech, Inc.
 Registration Statement on Form S-3
 Filed July 11, 2025
 File No. 333-288638
Dear Joel L. Fruendt:

 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: Katherine A. Beck, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 SenesTech, Inc.
13430 North Dysart Road, Suite 105

 Surprise, Arizona 85379

 July 16, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, N.E.

 Washington, DC 20549

 Attention: Margaret Sawicki

 Re: SenesTech, Inc.
Registration Statement on Form S-3
File No. 333-288638

 Ladies and Gentlemen:

 In accordance with Rule 461
under the Securities Act of 1933, as amended, SenesTech, Inc. (the " Company ") hereby requests that the effective date
of the above-captioned Registration Statement on Form S-3 (the " Registration Statement "), be accelerated to 4:00 p.m.,
Eastern time, on Friday, July 18, 2025, or as soon as practicable thereafter. Once the Registration Statement has been declared effective,
please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck at (602) 445-8349 or, in her absence,
Brian H. Blaney at (602) 445-8322.

 The Company acknowledges that
(1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not
foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 [signature page follows]

 Very truly yours,

 SENESTECH, INC.

 By:
 /s/ Thomas C. Chesterman

 Name:
 Thomas C. Chesterman

 Title:
 Executive Vice President, Chief Financial Officer, Treasurer and Secretary

CORRESP
 1
 filename1.htm

 SenesTech, Inc.
13430 North Dysart Road, Suite 105

 Surprise, Arizona 85379

 June 23, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, N.E.

 Washington, DC 20549

 Attention: Juan Grana

 Re: SenesTech, Inc.
Registration Statement on Form S-3
File No. 333-288097

 Ladies and Gentlemen:

 In accordance with Rule 461
under the Securities Act of 1933, as amended, SenesTech, Inc. (the " Company ") hereby requests that the effective date
of the above-captioned Registration Statement on Form S-3 (the " Registration Statement "), be accelerated to 4:00 p.m.,
Eastern time, on Tuesday, June 24, 2025, or as soon as practicable thereafter. Once the Registration Statement has been declared effective,
please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck at (602) 445-8349 or, in her absence,
Brian H. Blaney at (602) 445-8322.

 The Company acknowledges that
(1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not
foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 [signature page follows]

 Very truly yours,

 SENESTECH, INC.

 By:
 /s/ Thomas C. Chesterman

 Name:
 Thomas C. Chesterman

 Title:
 Executive Vice President, Chief Financial Officer, Treasurer and Secretary

CORRESP
 1
 filename1.htm

 SenesTech, Inc.
13430 North Dysart Road, Suite 105

 Surprise, Arizona 85379

 June 23, 2025

 Via EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Industrial Applications and Services
100 F Street, N.E.

 Washington, DC 20549

 Attention: Margaret Sawicki

 Re: SenesTech, Inc.
Registration Statement on Form S-3
File No. 333-286955

 Ladies and Gentlemen:

 In accordance with Rule
461 under the Securities Act of 1933, as amended, SenesTech, Inc. (the " Company ") hereby requests that the
effective date of the above-captioned Registration Statement on Form S-3 (the " Registration Statement "), be
accelerated to 5:00 p.m., Eastern time, on Tuesday, June 24, 2025, or as soon as practicable thereafter. Once the
Registration Statement has been declared effective, please orally confirm that event with our counsel, Greenberg Traurig, LLP, by
calling Katherine A. Beck at (602) 445-8349 or, in her absence, Brian H. Blaney at (602) 445-8322.

 The Company acknowledges that
(1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not
foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 [signature page follows]

 Very truly yours,

 SENESTECH, INC.

 By:
 /s/ Thomas C. Chesterman

 Name:
 Thomas C. Chesterman

 Title:
 Executive Vice President, Chief Financial Officer, Treasurer and Secretary

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 23, 2025

Joel Fruendt
Chief Executive Officer
SenesTech, Inc.
13430 North Dysart Road, Suite 105
Surprise, AZ 85379

 Re: SenesTech, Inc.
 Registration Statement on Form S-3
 Filed June 17, 2025
 File No. 333-288097
Dear Joel Fruendt:

 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 Juan Grana at 202-551-6034 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Brian H. Blaney, Esq.
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 7, 2025

Joel L. Fruendt
President and Chief Executive Officer
SenesTech, Inc.
13430 North Dysart Road, Suite 105
Surprise, Arizona 85379

 Re: SenesTech, Inc.
 Registration Statement on Form S-3
 Filed May 2, 2025
 File No. 333-286955
Dear Joel L. Fruendt:

 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: Katherine A. Beck, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N. 19th Ave., Suite 110

Phoenix, Arizona 85027

October 2, 2024

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, DC 20549

Attention: Jane Park

 Re: SenesTech, Inc.

Registration Statement on Form S-3

File No. 333-282286

Ladies and Gentlemen:

In accordance with Rule 461
under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests that the effective date
of the above-captioned Registration Statement on Form S-3 (the “Registration Statement”), be accelerated to 4:00 p.m.,
Eastern time, on Friday, October 4, 2024, or as soon as practicable thereafter. Once the Registration Statement has been declared effective,
please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck at (602) 445-8349 or, in her absence,
Brian H. Blaney at (602) 445-8322.

The Company acknowledges that
(1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not
foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[signature page follows]

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

September 27, 2024
Joel Fruendt
President and Chief Executive Officer
SenesTech, Inc.
23460 N. 19th Ave., Suite 110
Phoenix, Arizona 85027
Re:SenesTech, Inc.
Registration Statement on Form S-3
Filed September 23, 2024
File No. 333-282286
Dear Joel Fruendt:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that
the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jane Park at 202-551-7439 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Katherine Beck, Esq.

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N. 19th Ave., Suite 110

Phoenix, Arizona 85027

November 27, 2023

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Washington, DC 20549

Attention: Jessica Ansart

 Re: SenesTech, Inc.

Registration Statement on Form S-1, as amended

File No. 333-273370

Ladies and Gentlemen:

In accordance with Rule 461
under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests that the effective date
of the above-captioned Registration Statement on Form S-1, as amended (the “Registration Statement”), be accelerated
to 5:15 p.m., Eastern time, on Monday, November 27, 2023, or as soon as practicable thereafter. Once the Registration Statement has been
declared effective, please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck at (602) 445-8349
or, in her absence, Brian H. Blaney at (602) 445-8322.

The Company acknowledges that
(1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not
foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[signature page follows]

    Very truly yours,

    SENESTECH, INC.

    By:
     /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

CORRESP
1
filename1.htm

November 27, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

Washington, DC 20549

    Re:

    SenesTech, Inc.

    Registration Statement on Form S-1 (Registration No. 333-273370),
as amended - Concurrence in Acceleration Request

Ladies and Gentlemen:

H.C. Wainwright & Co.,
LLC (“Wainwright”), solely acting as placement agent on a best efforts basis in an offering pursuant to the registration
statement on Form S-1 (333-273370), as amended (the “Registration Statement”), hereby concurs in the request by SenesTech,
Inc. that the effective date of the above-referenced registration statement be accelerated to 5:15 P.M. (Eastern Time), or as soon as
practicable thereafter, on November 27, 2023, pursuant to Rule 461 under the Securities Act. Wainwright affirms that it is aware of its
obligations under the Securities Act as they pertain to the best efforts offering pursuant to the Registration Statement.

    Very truly yours,

    H.C. WAINWRIGHT & CO., LLC

    By:
    Mark V. Viklund

    Name:
    Mark W. Viklund

    Title:
    Chief Executive Officer

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N. 19th Ave., Suite 110

Phoenix, Arizona 85027

October 13, 2023

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, N.E.

Washington, DC 20549

Attention: Juan Grana

 Re: SenesTech, Inc.

Registration Statement on Form S-3

File No. 333-274894

Ladies and Gentlemen:

In accordance with Rule 461
under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests that the effective date
of the above-captioned Registration Statement on Form S-3 (the “Registration Statement”), be accelerated to 5:00 p.m.,
Eastern time, on Tuesday, October 17, 2023, or as soon as practicable thereafter. Once the Registration Statement has been declared effective,
please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck at (602) 445-8349 or, in her absence,
Brian H. Blaney at (602) 445-8322.

The Company acknowledges
that (1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does
not foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United
States.

[signature page follows]

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

United States securities and exchange commission logo
October 13, 2023
Joel L. Fruendt
President and Chief Executive Officer
SenesTech, Inc.
23460 N. 19th Ave., Suite 110
Phoenix, Arizona 85027
Re:SenesTech, Inc.
Registration Statement on Form S-3
Filed October 6, 2023
File No. 333-274894
Dear Joel L. Fruendt:
            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 Juan Grana at 202-551-6034 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Katherine Beck

United States securities and exchange commission logo
July 31, 2023
Joel Fruendt
President and Chief Executive Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, Arizona 85027
Re:SenesTech, Inc.
Registration Statement on Form S-1
Filed July 21, 2023
File No. 333-273370
Dear Joel Fruendt:
            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 Jessica Ansart at 202-551-4511 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Katherine Beck

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N. 19th Ave., Suite 110

Phoenix, Arizona 85027

November 15, 2022

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing

100 F Street, N.E.

Washington, DC 20549

Attention: Jane Park

 Re: SenesTech, Inc.

Registration Statement on Form S-1

File No. 333-267991

Ladies and Gentlemen:

In accordance with Rule 461
under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests that the effective date
of the above-captioned Registration Statement on Form S-1 (the “Registration Statement”), be accelerated to 1:00 p.m.,
Eastern time, on Wednesday, November 16, 2022, or as soon as practicable thereafter. Once the Registration Statement has been declared
effective, please orally confirm that event with our counsel, Greenberg Traurig, LLP, by calling Katherine A. Beck at (602) 445-8349 or,
in her absence, Brian H. Blaney at (602) 445-8322.

The Company acknowledges that
(1) should the Commission or staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not
foreclose the Commission from taking any action with respect to the filing, (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing, and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[signature page follows]

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

CORRESP
1
filename1.htm

November 15, 2022

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporate Finance

Washington, DC 20549

    Re:

    SenesTech, Inc.

    Registration Statement on Form S-1 (Registration No. 333-267991), as
    amended - Concurrence in Acceleration Request

Ladies and Gentlemen:

H.C. Wainwright & Co., LLC
(“Wainwright”), solely acting as placement agent on a best efforts basis in an offering pursuant to the registration
statement on Form S-1 (333-267991), as amended (the “Registration Statement”), hereby concurs in the request by SenesTech,
Inc. that the effective date of the above-referenced registration statement be accelerated to 1:00 P.M. (Eastern Time), or as soon as
practicable thereafter, on November 16, 2022, pursuant to Rule 461 under the Securities Act. Wainwright affirms that it is aware of its
obligations under the Securities Act as they pertain to the best efforts offering pursuant to the Registration Statement.

    Very truly
yours,

    H.C. WAINWRIGHT & CO., LLC

    By:
    /s/ Edward D. Silvera

    Name: Edward D. Silvera
Title:   Chief Operating Officer

United States securities and exchange commission logo
October 31, 2022
Kenneth Siegel
Chief Executive Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, Arizona 85027
Re:SenesTech, Inc.
Registration Statement on Form S-1
Filed October 24, 2022
File No. 333-267991
Dear Kenneth Siegel:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Jane Park at 202-551-7439 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:       Katherine Beck, Esq.

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N 19th Avenue, Suite 110

Phoenix, Arizona 85027

May 4, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Tyler Howes

 Re: SenesTech, Inc.

Registration Statement on Form S-3 (the “Registration Statement”)

Filed as of November 19, 2021

File No. 333-261227

Dear Mr. Howes:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby
requests that the effective date of the above-captioned Registration Statement be accelerated to 5:00 p.m., Eastern time, on Friday, May
6, 2022, or as soon as practicable thereafter.

The Company acknowledges that:

(1) should
the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose
the Commission from taking any action with respect to the Registration Statement;

(2) the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does
not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(3) the
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please provide a copy of the
Commission’s order declaring the Registration Statement effective to Thomas C. Chesterman at the address first set forth above.

    Very truly
    yours,

    SENESTECH, INC.

    By:
    /s/ Thomas
    C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N 19th Avenue, Suite 110

Phoenix, Arizona 85027

March 31, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Tyler Howes

 Re: SenesTech, Inc.

Registration Statement on Form S-3 (the “Registration Statement”)

Filed as of November 19, 2021

File No. 333-261227

Dear Mr. Howes:

Reference is hereby made to
our letter, filed as correspondence via EDGAR on March 29, 2022, in which we requested that the effective date of the above-captioned
Registration Statement be accelerated to 5:00 p.m., Eastern time, on Thursday, March 31, 2022, or as soon as practicable thereafter, in
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended. Pursuant to our conversation
with the staff of the Securities and Exchange Commission, we hereby formally withdraw such request for acceleration of effectiveness.
We plan to submit a new request for acceleration of effectiveness at a later date.

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

CORRESP
1
filename1.htm

SenesTech, Inc.

23460 N 19th Avenue, Suite 110

Phoenix, Arizona 85027

March 29, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Tyler Howes

 Re: SenesTech, Inc.

Registration Statement on Form S-3 (the “Registration Statement”)

Filed as of November 19, 2021

File No. 333-261227

Dear Mr. Howes:

In accordance with Rule
461 of the General Rules and Regulations under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby
requests that the effective date of the above-captioned Registration Statement be accelerated to 5:00 p.m., Eastern time, on Thursday,
March 31, 2022, or as soon as practicable thereafter.

The Company acknowledges
that:

(1)       should
the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose
the Commission from taking any action with respect to the Registration Statement;

(2)       the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does
not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

(3)       the
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please provide a copy of
the Commission’s order declaring the Registration Statement effective to Thomas C. Chesterman at the address first set forth above.

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:

    Title:

    Thomas C. Chesterman

Chief Financial Officer

United States securities and exchange commission logo
November 26, 2021
Tom Chesterman
Chief Financial Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, AZ 85027
Re:SenesTech, Inc.
Registration Statement on Form S-3
Filed November 19, 2021
File No. 333-261227
Dear Mr. Chesterman:
            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 Tyler Howes at 202-551-3370 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Chris Hall, Esq.

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SenesTech, Inc.

23460 N 19th Ave., Suite 110

Phoenix, AZ 85027

Telephone: (928) 779-4143

February 8, 2021

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    SenesTech, Inc.

    Registration Statement on Form S-3

    Filed as of February 2, 2021

    File No. 333-252665

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests acceleration of the effective date
of its Registration Statement on Form S-3 (File No. 333-252665) (the “Registration Statement”), so that it may
become effective at 5:00 p.m., Eastern Time, on Tuesday, February 9, 2021, or as soon as practicable thereafter.

The Company requests the Commission confirm
the effective date and time of the Registration Statement to June Wang of Perkins Coie LLP, counsel to the Company, by telephone
at (646) 269-0687.

    Respectfully Submitted,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

 cc: June Wang (Perkins Coie LLP)

United States securities and exchange commission logo
February 8, 2021
Kenneth Siegel
Chief Executive Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, AZ 85027
Re:SenesTech, Inc.
Registration Statement on Form S-3
Filed February 2, 2021
File No. 333-252665
Dear Mr. Siegel:
            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 Kasey Robinson at 202-551-5880 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       June Wang

United States securities and exchange commission logo
December 11, 2020
Kenneth Siegel
Chief Executive Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, AZ 85027
Re:SenesTech, Inc.
Registration Statement on Form S-1
Filed December 7, 2020
File No. 333-251173
Dear Mr. Siegel:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Chris Edwards at 202-551-6761 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kara Tatman

CORRESP
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SenesTech, Inc.

23460 N 19th Ave., Suite 110

Phoenix, AZ 85027

Telephone: (928) 779-4143

December 14, 2020

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    SenesTech, Inc.

    Registration Statement on Form S-1

    Filed as of December 7, 2020

    File No. 333-251173

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests acceleration of the effective date of its
Registration Statement on Form S-1 (File No. 333-251173) (the “Registration Statement”), so that it may become
effective at 4:30 p.m., Eastern Time, on Wednesday, December 16, 2020, or as soon as practicable thereafter.

The Company requests the Commission confirm
the effective date and time of the Registration Statement to Chris Hall of Perkins Coie LLP, counsel to the Company, by telephone
at (503) 727-2048.

    Respectfully Submitted,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

cc:	Chris Hall (Perkins Coie LLP)

CORRESP
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SenesTech, Inc.

23460 N 19th Ave., Suite 110

Phoenix, AZ 85027

Telephone: (928) 779-4143

February 13, 2020

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    SenesTech, Inc.

    Registration Statement on Form S-1

    Filed as of February 11, 2020

    File No. 333-236359

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests acceleration of the
effective date of its Registration Statement on Form S-1 (File No. 333-236359) (the “Registration Statement”),
so that it may become effective at 4:00 p.m., Eastern Time, on Friday, February 14, 2020, or as soon as practicable thereafter.

The Company requests the
Commission confirm the effective date and time of the Registration Statement to Chris Hall of Perkins Coie LLP, counsel to the
Company, by telephone at (503) 727-2048.

    Respectfully Submitted,

    SENESTECH, INC.

    By:
    /s/ Thomas C. Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

    cc:
    Chris Hall (Perkins Coie LLP)

February 13, 2020
Tom Chesterman
Chief Financial Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, AZ 85027
Re:SenesTech, Inc.
Registration Statement on Form S-1
Filed February 11, 2020
File No. 333-236359
Dear Mr. Chesterman:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Courtney Lindsay at (202) 551-7237 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kara Tatman

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February
12, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance 100 F Street, NE

Washington, D.C. 20549

Attention: Courtney Lindsay

    Re:

        SenesTech, Inc.

        Registration Statement on Form S-l

        File No. 333-236302

Ladies and Gentlemen:

H.C. Wainwright & Co.,
LLC (“Wainwright”), as placement agent for the referenced offering, hereby concurs in the request by SenesTech, Inc.
that the effective date of the above-referenced registration statement be accelerated to 4:00 p.m. Eastern Time on Friday February
14, 2020, or as soon as practicable thereafter, pursuant to Rule 461 under the Securities Act. Wainwright affirms that it is aware
of its obligations under the Securities Act in connection with this offering.

    Very truly yours,

    H.C. WAINWRIGHT & CO., LLC

    By:
    Edward D. Silvera

    Name:
    Edward D. Silvera

    Title:
    Chief Operating Officer

CORRESP
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SenesTech,
Inc.

23460
N 19th Ave., Suite 110

Phoenix,
AZ 85027

Telephone:
(928) 779-4143

February
12, 2020

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    SenesTech,
    Inc.

    Registration
    Statement on Form S-1

    Filed
    as of February 7, 2020

    File
    No. 333-236302

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests acceleration
of the effective date of its Registration Statement on Form S-1 (File No. 333-236302) (the “Registration Statement”),
so that it may become effective at 4:00 p.m., Eastern Time, on Friday, February 14, 2020, or as soon as practicable thereafter.

The
Company requests the Commission confirm the effective date and time of the Registration Statement to Chris Hall of Perkins Coie
LLP, counsel to the Company, by telephone at (503) 727-2048.

    Respectfully
    Submitted,

    SENESTECH,
    INC.

    By:
    /s/ Thomas C.
    Chesterman

    Name:
    Thomas C. Chesterman

    Title:
    Chief Financial Officer

    cc:
    Chris Hall (Perkins Coie LLP)

February 11, 2020
Tom Chesterman
Chief Financial Officer
SenesTech, Inc.
23460 N 19th Ave., Suite 110
Phoenix, AZ 85027
Re:SenesTech, Inc.
Registration Statement on Form S-1
Filed February 7, 2020
File No. 333-236302
Dear Mr. Chesterman:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Courtney Lindsay at (202) 551-7237 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Kara Tatman

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SenesTech, Inc.

3140 N. Caden Court, Suite 1

Flagstaff, AZ 86004

Telephone: (928) 779-4143

August 22, 2018

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    SenesTech, Inc.

    Registration Statement on Form S-3

    Initially filed June 19, 2018, as amended

    File No. 333-225712

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests acceleration of the effective date of its
Registration Statement on Form S-3 (File No. 333-225712), as amended (the “Registration Statement”), so that
it may become effective at 9:00 a.m., Eastern Time, on Friday, August 24, 2018, or as soon as practicable thereafter.

The Company requests the Commission confirm
the effective date and time of the Registration Statement to Chris Hall of Perkins Coie LLP, counsel to the Company, by telephone
at (503) 727-2048.

Respectfully Submitted,

SENESTECH, INC.

By:  /s/ Thomas C. Chesterman

Name: Thomas C. Chesterman

Title: Chief Financial Officer

cc:	Chris Hall (Perkins Coie LLP)

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August 14, 2018

Office of Transportation and Leisure

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: John Stickel

   Susan Block

Re:        SenesTech, Inc.

Registration Statement on Form S-3

Filed June 19, 2018

File No. 333-225712

Dear Mr. Stickel and Ms. Block,

This letter is submitted on behalf of SenesTech,
Inc. (“SenesTech”) in response to comments by the staff of the Securities and Exchange Commission (the “SEC”)
relating to the SenesTech’s Registration Statement on Form S-3 filed June 19, 2018 (File No. 333-225712) (the “Registration
Statement”). For your ease of reference, our responses to your comments are numbered in a corresponding manner:

Form S-3 filed June 19, 2018

General

1. We note your intent to rely on General
Instruction I.B.6 to Form S-3 for limited primary offerings. Please disclose on the prospectus cover page the information called
for by Instruction 7 to General Instruction I.B.6. Please also confirm to us your understanding of the size limitations for offerings
made under General Instruction I.B.6.

Response: We acknowledge the SEC’s
comment and have filed an amendment to the Registration Statement to disclose on the prospectus cover page the information called
for by Instruction 7 to General Instruction I.B.6. We also confirm and acknowledge the size limitations for offerings made under
General Instruction I.B.6.

If you would like to discuss any of the
matters contained in this letter, please feel free to contact our counsel, Chris Hall at (503) 727-2048, or Gina Eiben at (503)
727-2059 at Perkins Coie LLP.

[signature page follows]

Sincerely,

    /s/ Thomas C. Chesterman

    Thomas C. Chesterman

        Chief Financial Officer

        SenesTech, Inc.

CORRESP
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SenesTech,
Inc.

3140
N. Caden Court, Suite 1

Flagstaff,
AZ 86004

Telephone:
(928) 779-4143

July
23, 2018

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    SenesTech, Inc.

    Registration Statement on Form S-1

    Initially filed June 19, 2018, as amended

    File No. 333-225713

Ladies
and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, SenesTech, Inc. (the “Company”) hereby requests acceleration
of the effective date of its Registration Statement on Form S-1 (File No. 333-225713), as amended (the “Registration Statement”),
so that it may become effective at 9:00 a.m., Eastern Time, on Wednesday, July 25, 2018, or as soon as practicable thereafter.

The
Company requests the Commission confirm the effective date and time of the Registration Statement to Chris Hall of Perkins Coie
LLP, counsel to the Company, by telephone at (503) 727-2048.

    Respectfully Submitted,

    SENESTECH, INC.

    By:
        /s/
    Thomas C. Chesterman

    Name: Thomas C.
    Chesterman

    Title:   Chief Financial Officer

cc: Chris
Hall (Perkins Coie LLP)

July 13, 2018
Loretta P. Mayer, Ph.D
Chief Executive Officer and Chief Scientific Officer
SenesTech, Inc.
3140 N. Caden Court, Suite 1
Flagstaff, AZ 86004
Re:SenesTech, Inc.
Registration Statement on Form S-3
Filed June 19, 2018
File No. 333-225712
Dear Ms. Mayer:
            We have limited our review of your registration statement to those issues we have
addressed in our 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.
Form S-3 filed June 19, 2018
General
1.We note your intent to rely on General Instruction I.B.6 to Form S-3 for limited primary
offerings.  Please disclose on the prospectus cover page the information called for by
Instruction 7 to General Instruction I.B.6.  Please also confirm to us your understanding of
the size limitations for offerings made under General Instruction I.B.6.
            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.

 FirstName LastNameLoretta P. Mayer, Ph.D
 Comapany NameSenesTech, Inc.
 July 13, 2018 Page 2
 FirstName LastName
Loretta P. Mayer, Ph.D
SenesTech, Inc.
July 13, 2018
Page 2
            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.
            Please contact John Stickel at 202-551-3324 or Susan Block at 202-551-3210 with any
questions.
Division of Corporation Finance
Office of Transportation and Leisure

June 26, 2018
Loretta P. Mayer, Ph.D
Chief Executive Officer and Chief Scientific Officer
SenesTech, Inc.
3140 N. Caden Court, Suite 1
Flagstaff, AZ 86004
Re:SenesTech, Inc.
Registration Statement on Form S-1
Filed June 19, 2018
File No. 333-225713
Dear Mr. Mayer:
            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 John Stickel at 202-551-3324 with any questions.
Division of Corporation Finance
Office of Transportation and Leisure

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November 13, 2017

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

    Re:

        SenesTech, Inc.

        Acceleration
        Request for Registration Statement on Form S-1, filed on November 8, 2017 (File No. 333-221433)

Dear 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,
Roth Capital Partners, LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday, November 15, 2017, 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
confirms that it has complied with and will continue to comply with, and it has been informed or will be informed by participating
dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as
amended, in connection with the above-referenced issue.

Very truly yours,

/s/ Aaron M. Gurewitz

Aaron M. Gurewitz

Head of Equity Capital Markets

BJW

        ANNARBOR 50520-11 179058v1

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November 13, 2017

U.S. Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

 Re: SenesTech, Inc. (the “Company”)

    Acceleration Request for Registration Statement on
Form S-1, filed on November 8, 2017 (File No. 333-221433)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended
(the “Securities Act”), the Company hereby requests that the effective date of the above-referenced Registration Statement
be accelerated so that it becomes effective at 4:30 p.m., Eastern Time, on Wednesday, November 15, 2017, or at such other time
as the Company may request by telephone to the Securities and Exchange Commission. The Company authorizes Chris Hall and Jared
Forsgren, each at Perkins Coie LLP, counsel to the Company, to make any such request on its behalf.

  Sincerely,

  SENESTECH INC.

  /s/ Thomas C. Chesterman

  Name:	 Thomas C. Chesterman

 Title: Chief Financial Officer

Mail Stop 3561
November 7 , 2017

Thomas C. Chesterman
Chief Financial Officer
SenesTech, Inc.
3140 N. Caden Court
Suite 1
Flagstaff, AZ  86004

Re: SenesTech, Inc.
 Form 10-K for  Fiscal Year Ended December 31, 2016
Filed March 31, 2017
File No. 001 -37941

Dear Mr. Chesterman :

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

Sincerely,

 /s/ Lyn Shenk

Lyn Shenk
Branch Chief
Office of Transportation and Leisure

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November
6, 2017

Lyn
Shenk, Branch Chief

Office
of Transportation and Leisure

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

 Re: SenesTech,
Inc.

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

    Filed
                                         March 31, 2017

    File
                                         No. 001-37941

Dear
Mr. Shenk:

This
letter is submitted on behalf of SenesTech, Inc. (“SenesTech”) after obtaining further clarification to
the comments by the staff of the Securities and
Exchange Commission (the “SEC”) relating to the Company’s Form 10-K for the fiscal year ended
December 31, 2016 (the “2016 Form 10-K”). For your convenience, we have restated the comments below from
your letter date October 31, 2017, followed by SenesTech’s responses. Page numbers in the responses refer to the 2016
Form 10-K as originally filed.

Risks
Related to Our Business Operations and History

 1. We
                                         note your disclosure in the second risk factor on page 23 that “We have not been
                                         required to and have not filed an annual report for fiscal 2016, so pursuant to SEC regulations,
                                         we are not yet required to evaluate the effectiveness of our internal control over financial
                                         reporting.” As this document is your annual report for fiscal 2016, please revise
                                         your disclosure to comply with Instruction 1 to Item 308 of Regulation S-K to include
                                         a statement regarding the transition period established for newly public companies.

Response
to Comment No. 1:

The
Company intends to amend its Annual Report on Form 10-K for the fiscal year ended December 31, 2016 to modify the risk factor
disclosure to clarify our requirement to evaluate the effectiveness of our internal control over financial reporting.

Note
2: Summary of Significant Accounting Policies

 2. Please
                                         expand your disclosure here and in your Form 10-Q’s to provide the information
                                         in SAB Topic 11:M for FASB ASU 2014-09, Revenue from Contracts with Customers (Topic
                                         606).

Response
to Comment No. 2:

The
Company intends to amend its Annual Report on Form 10-K for the fiscal year ended December 31, 2016, its Quarterly Report on Form
10-Q for the quarterly period ended March 31, 2017 and its Quarterly Report on Form 10-Q for the quarterly period ended June 30,
2017 to expand our disclosure to provide the information in SAB Topic 11:M for FASB ASU 2014-09, Revenue from Contracts with
Customers (Topic 606).

If
you would like to discuss any of the matters contained in this letter, please feel free to contact our counsel, Jared
Forsgren at (503) 727-2108 or Chris Hall at (503) 727-2048, at Perkins Coie LLP.

Sincerely,

    /s/
    Thomas C. Chesterman

    Thomas
C. Chesterman

        Chief
Financial Officer

        SenesTech,
Inc.

    2

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November 1, 2017

Lyn Shenk, Branch Chief

Office of Transportation and Leisure

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: 	SenesTech, Inc.

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

Filed March 31, 2017

File No. 001-37941

Dear Mr. Shenk:

We have reviewed your letter of October
31, 2017 to us setting forth staff comments on the SenesTech, Inc. (“SenesTech”) Form 10-K for the fiscal year
ended December 31, 2016 (the “2016 Form 10-K”). For your convenience, we have restated the comments below, followed
by SenesTech’s responses. Page numbers in the responses refer to the 2016 Form 10-K as originally filed.

Risks Related to Our Business Operations and History

 1. We note your disclosure in the second risk factor on page 23 that “We have not been required
to and have not filed an annual report for fiscal 2016, so pursuant to SEC regulations, we are not yet required to evaluate the
effectiveness of our internal control over financial reporting.” As this document is your annual report for fiscal 2016,
please revise your disclosure to comply with Instruction 1 to Item 308 of Regulation S-K to include a statement regarding the transition
period established for newly public companies.

Response to Comment No. 1:

We refer you to the following disclosure in Item 9A. Controls
and Procedures — Evaluation of Disclosure Controls and Procedures on page 43 of our 2016 10-K.

This annual report does not
include a report of management's assessment regarding internal control over financial reporting or an attestation report of the
company's registered public accounting firm due to a transition period established by rules of the Securities and Exchange Commission
for newly public companies.

For future filings, we will modify our risk factor disclosure
to clarify our requirement to evaluate the effectiveness of our internal control over financial reporting. Below is the disclosure
we intend to include in our future filings, including our Form 10-Q for the quarter ended September 30, 2017 and any filings that incorporate our 2016 10-K by reference.

We have not fully assessed
our internal control over financial reporting. We have previously identified and may in the future identify material weaknesses
in our internal control over financial reporting. If we are unable to remediate these material weaknesses, or if we experience
additional material weaknesses in the future or otherwise fail to maintain an effective system of internal controls, we may not
be able to accurately or timely report our financial condition or results of operations, which may adversely affect investor confidence
in us and, as a result, the value of our common stock.

In connection with the preparation
of our consolidated financial statements as of and for the year ended December 31, 2015, we identified material weaknesses in our
internal control over financial reporting. A material weakness is a deficiency, or combination of deficiencies, in internal control
over financial reporting such that there is a reasonable possibility that a material misstatement of our financial statements will
not be prevented or detected on a timely basis. We have addressed and resolved the issues identified in 2015.

We have or are in the process
of implementing measures designed further to improve our internal control over financial reporting, including how to remediate
the control deficiencies that led to our previously identified material weaknesses, including:

 · the appointment of a Corporate Controller in May 2016;

 · the establishment of formalized accounting policies and procedures and internal
controls; and

 · the implementation of manual and automated controls to support our overall
control environment and the segregation of duties and procedures.

In our annual report for
the year ended December 31, 2016, we were not required to evaluate the effectiveness of our internal control over financial
reporting. Similarly, because we are an emerging growth company, we were not required to include an auditor attestation
report on our internal control over financial reporting in our annual report for the year ended December 31, 2016. As a
result, we have not yet fully assessed our internal control over financial reporting and are unable to assure that the
measures we have taken to date, together with any measures we may take in the future, will be sufficient to remediate the
control deficiencies that led to our material weaknesses in our internal control over financial reporting, or to avoid
potential future material weaknesses.

If we are unable to maintain
an effective system of internal control over financial reporting, successfully remediate any existing or future material weaknesses
in our internal control over financial reporting, or identify any additional material weaknesses, the accuracy and timing of our
financial reporting may be adversely affected, we may be unable to maintain compliance with securities law requirements regarding
timely filing of periodic reports in addition to Nasdaq listing requirements, investors may lose confidence in our financial reporting,
and our stock price may decline as a result.

Note 2: Summary of Significant Accounting Policies

2.
Please expand your disclosure here and in your Form 10-Q’s to provide the information in SAB Topic 11:M for FASB ASU
2014-09, Revenue from Contracts with Customers (Topic 606).

Response to Comment No. 2:

In future filings, SenesTech will include
additional information regarding the status of its implementation of ASU No. 2014-09, Revenue from Contracts with Customers
(Topic 606), including disclosures outlined in SAB Topic 11.M. Below is the disclosure we will include in our future filings, including our Form 10-Q for the quarter ended September 30, 2017 and any filings that incorporate our 2016 10-K by reference. The disclosure below may be revised as necessary to comply with additional ASUs or to provide additional clarity until we
adopt the new standard.

In May 2014 the FASB
issued ASU No. 2014-09, Revenue from Contracts with Customers. Since ASU 2014-09 was issued, several additional ASUs have
been issued to clarify various elements of the guidance. These standards provide guidance on recognizing revenue, including a
five-step model to determine when revenue recognition is appropriate. The standard requires that an entity recognize revenue
to depict the transfer of control of promised goods or services to customers in an amount that reflects the consideration to
which the entity expects to be entitled in exchange for those goods or services. Adoption of the new standard is effective
for reporting periods beginning after December 15, 2017. We plan to use the modified retrospective method of adoption and
will adopt the standard as of January 1, 2018, the beginning of our next fiscal year. We have completed an initial evaluation
of the potential impact from adopting the new standard, including a detailed review of performance obligations for all
material revenue streams. Based on this initial evaluation, we do not expect adoption will have a material impact on our
financial position, results of operations, or cash flows. Related disclosures will be expanded in line with the requirements
of the standard. We will continue our evaluation until our adoption of the new standard.

If you would like to discuss any of the
matters contained in this letter, please feel free to contact me at (928) 779-4143.

Sincerely,

    /s/ Thomas C. Chesterman

        Thomas C. Chesterman

        Chief Financial Officer

        SenesTech, Inc.

Mail Stop 3561
November 1 , 2017

Loretta P. Mayer, Ph.D.
Chief Executive Officer
SenesTech, Inc.
3140 N. Caden Court, Suite 1
Flagstaff, AZ 86004

Re: SenesTech, Inc.
  Draft Registration Statement on Form S-1
Submitted  October 20, 2017
  CIK  No. 0001680378

Dear Dr. Mayer :

We have conducted a limited review of your draft registration statement.  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 providing any requested information  and by publicly
filing your registration statement and non -public draft submission on EDGAR .  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 the information you provide in response to these  comments  and your
filed registration statement , we may have  additional comments.

General

1. We note that you have outstanding comments related to your Form 10 -K for the fiscal
year ended December 31, 201 6 and subsequent quarterly reports .  Please note that all
comments on your Form 10 -K and subsequent quarterly reports  will need to be fully
resolved before we act on a request for acceleration of the effectiveness of the F orm S -1.

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.

Loretta P. Mayer, Ph.D.
SenesTech, Inc.
November 1 , 2017
Page 2

We also remind you that your registration statement  must be on file  no later than 48 hours
prior to the requested effective date and ti me.  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.

Please contact Donald E. Field  at (202) 551 -3680 or me at (202) 551 -3469 with any
questions.

Sincerely,

 /s/ Justin Dobbie

Justin Dobbie
Legal Branch Chief
Office of Transportation and Leisure

cc: Jared Forsgren
 Perkins Coie LLP

Mail Stop 3561
October 31, 2017

Thomas C. Chesterman
Chief Financial Officer
SenesTech, Inc.
3140 N. Caden Court
Suite 1
Flagstaff, AZ  86004

Re: SenesTech, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2016
Filed March 31, 2017
File No. 001-37941

Dear Mr. Chesterman :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some  of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will re spond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

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

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

Risks Related to Our Business Operations and History, page 22

1. We note your disclosure in the second risk factor on page 23 that “We have not been
required to and have not filed an annual report for fiscal 2016, so pursuant to SEC
regulations, we are not  yet required to evaluate the effectiveness of our internal control
over financial reporting.”  As this document is your annual report for fiscal 2016, please
revise your disclosure to comply with Instruction 1 to Item 308 of Regulation S -K to
include a st atement regarding the transition period established for newly public
companies.

Thomas C. Chesterman
SenesTech, Inc.
October 31, 2017
Page 2

 Note 2:  Summary of Significant Accounting Policies, page F -12

2. Please expand your disclosure here and in your Form 10 -Q’s to provide the information
in SAB Topic 11:M fo r FASB ASU 2014 -09, Revenue from Contracts with Customers
(Topic 606).

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 Theresa Brillant  at 202-551-3307 or me  at 202-551-3380  if you have
questions regarding comments on the financial statements and rel ated matters.

Sincerely,

 /s/ Lyn Shenk

Lyn Shenk
Branch Chief
Office of Transportation and Leisure

CORRESP
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December 5, 2016

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

    Re:

        SenesTech, Inc.

        File No: 333-213736

        Registration Statement on Form S-1, Amendment No. 5

Dear 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,
Roth Capital Partners, LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:30 p.m., Eastern Time, on Wednesday, December 7, 2016, 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 confirms
that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers
that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.

Very truly yours,

/s/ Aaron M. Gurewitz

Aaron M. Gurewitz

Head of Equity Capital Markets

BJW

CORRESP
1
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SENESTECH, INC.

December 5, 2016

VIA EDGAR

United States Securities and Exchange Commission (the “Commission”)
 Division of Corporation Finance
 100 F. Street, N.E.
 Mail Stop 3561
 Washington, D.C. 20549

    Attn.:
    Ms. Anne Nguyen Parker Assistant Director

                                                                  Office of Transportation and Leisure

        Re: SenesTech, Inc. (the “Company”)

        Registration Statement on Form S-1, as amended

        File No. 333-213736

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred
to above be accelerated so that it will be declared effective at 4:30 p.m., Eastern time on December 7, 2016, or as soon thereafter
as is practicable.

The Company hereby acknowledges that:

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

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

 · the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

        Very truly yours,

        SENESTECH, INC.

        By:

    /s/ Loretta P. Mayer Ph.D.

        Name:

    Loretta P. Mayer Ph.D.

    Title:
    Chief Executive Officer

CORRESP
1
filename1.htm

November 14, 2016

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

    Re:

        SenesTech, Inc.

        File No: 333-213736

        Registration Statement on Form S-1, Amendment No. 4

Dear 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,
Roth Capital Partners, LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 4:30 p.m., Eastern Time, on Monday, November 14, 2016, 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 confirms
that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers
that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.

    Very truly yours,

    /s/ Aaron M. Gurewitz

    Aaron M. Gurewitz

    Head of Equity Capital Markets

CORRESP
1
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SENESTECH, INC.

November 14, 2016

VIA EDGAR AND ELECTRONIC MAIL

United States Securities and Exchange Commission (the “Commission”)

Division of Corporation Finance

100 F. Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

    Attn.:
    Ms. Anne Nguyen Parker Assistant Director

    Office of Transportation and Leisure

Re: SenesTech, Inc. (the “Company”)

Registration Statement on Form S-1, Amendment No. 4

File No. 333-213736

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred
to above be accelerated so that it will be declared effective at 4:30 p.m., Eastern time on Monday, November 14, 2016, or
as soon thereafter as is practicable.

The Company hereby acknowledges that:

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

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

 · the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Loretta P. Mayer Ph.D.

    Name:  Loretta P. Mayer Ph.D.

    Title:  Chief Executive Officer

CORRESP
1
filename1.htm

    SENESTECH,
        INC.

    November
    14, 2016

VIA
EDGAR AND ELECTRONIC MAIL

United
States Securities and Exchange Commission (the “Commission”)

Division of Corporation Finance

100 F. Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

 Attn.: Ms.
                                         Anne Nguyen Parker Assistant Director

                                         Office of Transportation and Leisure

    Re:
        SenesTech, Inc. (the “Company”)

        Registration
        Statement on Form S-1, Amendment No. 4

        File
        No. 333-213736

Ladies
and Gentlemen:

Reference
is made to our letter, filed as correspondence via EDGAR on November 14, 2016, in which we requested the acceleration of
the effective date of the above-referenced Registration Statement for Monday, November 14, 2016, at 4:30 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 that time and we hereby withdraw our request for acceleration of the effective date until further notice.

    Very
    truly yours,

    SENESTECH,
    INC.

    By:
    /s/
    Loretta P. Mayer Ph.D.

    Name:
    Loretta P.
    Mayer Ph.D.

    Title:
    Chief Executive
    Officer

CORRESP
1
filename1.htm

SENESTECH, INC.

November 10, 2016

VIA EDGAR AND ELECTRONIC MAIL

United States Securities and Exchange Commission (the “Commission”)

Division of Corporation Finance

100 F. Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

 Attn.: Ms. Anne Nguyen Parker Assistant Director

Office
of Transportation and Leisure

Re:
SenesTech, Inc. (the “Company”)

Registration
Statement on Form S-1, as amended

File
No. 333-213736

Ladies and Gentlemen:

Reference
is made to our letter, filed as correspondence via EDGAR on November 7, 2016, in which we requested the acceleration of the effective
date of the above-referenced Registration Statement for Wednesday, November 9, 2016, 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 that time and we hereby withdraw our request for acceleration of the effective date until further notice.

    Very truly yours,

    SENESTECH, INC.

    By:
    /s/ Loretta P. Mayer Ph.D.

    Name:
    Loretta P. Mayer Ph.D.

    Title:
    Chief Executive Officer

CORRESP
1
filename1.htm

SENESTECH, INC.

November 7, 2016

VIA EDGAR AND ELECTRONIC MAIL

United States Securities and Exchange Commission (the “Commission”)

Division of Corporation Finance

100 F. Street, N.E.

Mail Stop 3561

Washington, D.C. 20549

 Attn.: Ms. Anne Nguyen Parker Assistant Director

Office of Transportation and Leisure

Re: SenesTech, Inc. (the “Company”)

Registration Statement on Form S-1, as amended

File No. 333-213736

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred
to above be accelerated so that it will be declared effective at 5:00 p.m., Eastern time on November 9, 2016, or as soon thereafter
as is practicable.

The Company hereby acknowledges that:

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

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

 · the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

        Very truly yours,

        SENESTECH, INC.

        By:/s/ Loretta P. Mayer Ph.D.

        Name: Loretta P. Mayer Ph.D.

        Title: Chief Executive Officer

CORRESP
1
filename1.htm

November 7, 2016

Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

    Re:

        SenesTech, Inc.

        File No: 333-213736

        Registration Statement on Form S-1, Amendment No. 3

Dear 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,
Roth Capital Partners, LLC, as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 5:00 p.m., Eastern Time, on Wednesday, November 9, 2016, 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 confirms
that it has complied with and will continue to comply with, and it has been informed or will be informed by participating dealers
that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended,
in connection with the above-referenced issue.

Very truly yours,

/s/ Aaron M. Gurewitz

Aaron M. Gurewitz

Head of Equity Capital Markets

BJW

CORRESP
1
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October 27, 2016

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3561

Washington, D.C. 20549-9303

 Attn.: Ms. Anne Nguyen Parker Assistant Director

Office of Transportation and Leisure

 Re: SenesTech, Inc.

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

Filed October 20, 2016

File No. 333-213736

Dear Ms. Parker:

On behalf of SenesTech,
Inc. (the “Company”), we submit this letter to you in connection with comments of the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filing, received
by the Company by letter dated October 26, 2016. In this letter, we have recited the comments of the Staff set forth in the October 26,
2016 letter in italicized type, and followed each comment with the Company’s response. Simultaneously herewith, the Company
is filing with the Commission an Amendment No. 3 to Registration Statement on Form S-1 (the “Registration Statement”),
an Issuer Free Writing Prospectus pursuant to Rule 433 under the Securities Act of 1933 (the “Free Writing Prospectus”)
and supplementally providing, for the Staff’s review, a version of the Registration Statement marked to show changes from
the Amendment No. 2 to Registration Statement on Form S-1 filed with the Commission on October 20, 2016. All page numbers refer
to the Registration Statement filed simultaneously herewith.

Staff Comment No. 1:

We note that the pro forma column in
the Balance Sheet Data on page 10 does not appear to be presented consist with its footnote disclosures. For example, the pro forma
column is described as reflecting the conversion of the convertible preferred stock into common stock and does not appear that
it should have an increase in cash or significant change in accumulated deficit. Also, additional paid in capital does not appear
appropriately calculated and it would appear the debt amounts in the actual column should carry over into the pro forma column.
Please revise appropriately.

      1

Company Response No. 1:

The Company has revised the Balance Sheet
Data on pages 10 and 30 of the Registration Statement to make the data consistent with the Company’s footnote disclosures
and to appropriately calculate additional paid-in capital. These revisions are reflected in the Free Writing Prospectus as well.

Staff Comment No. 2:

We note that the pro forma column on
the interim balance sheet appears to include the cash received and the issuance of the two million shares in this offering. Please
revise to remove the effects of the issuance of shares in this offering and only reflect the conversion of the preferred shares
to common stock.

Company Response No. 2:

The Company has revised the pro forma column
on the interim balance sheet on page F-40 of the Registration Statement to remove the effects of the issuance of shares in the
offering and only reflect the conversion of the preferred stock into common stock. These revisions are reflected in the Free Writing
Prospectus as well.

Staff Comment No. 3:

Refer to the registration statement
fee table. We note that you have registered the underwriters’ warrants and the common stock underlying those warrants. Please
have counsel revise the opinion to opine upon these registered securities.

Company Response No. 3:

The Company’s counsel has revised
its Exhibit 5.1 opinion to opine upon the validity of the underwriters’ warrants and the common stock underlying those warrants,
and a revised Exhibit 5.1 opinion has been filed with the Registration Statement which replaces the previously filed exhibit.

* * * * *

      2

Please direct all correspondence,
notices and orders issued with respect to this matter to the undersigned. If you would like to discuss this matter by telephone,
my direct line is (206) 676-7118.

    Sincerely,

    Summit Law Group, PLLC

    a professional limited liability company

    /s/ Andrew W. Shawber

    Andrew W. Shawber

 cc: Loretta P. Mayer and Thomas C. Chesterman (SenesTech,
Inc.)

Laura
A. Bertin

      3

Mail Stop 3561
October  26, 2016

Loretta P. Mayer
Chief Executive Officer
SenesTech, Inc.
3140 N. Caden Court, Suite 1
Flagstaff, AZ  86004

Re: SenesTech, Inc.
Amendment No. 2 to Registration Statement on Form S-1
Filed October 20, 2016
  File No. 333 -213736

Dear Dr. Mayer :

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 amen dment 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.

Summary Financial Data, page 9

Capitalization, page 30

1. We note that the pro forma column in the Balance Sheet Data on page 10 does not appear
to be presented consist with its footnote disclosures.  For example, the pro forma column
is described as reflecting the conversion of the conve rtible preferred stock into common
stock and does not appear that it should have an increase in cash or significant change in
accumulated deficit.  Also, additional paid in capital does not appear appropriately
calculated and it would appear the debt amoun ts in the actual column should carry over
into the pro forma column.   Please revise appropriately.

Loretta P. Mayer
SenesTech, Inc.
October  26, 2016
Page 2

Interim Financial Statements for the Six Months Ended June 30, 2016

Condensed Balance Sheets, page F -40

2. We note that the pro forma column on the interim balance sheet appears to include the
cash received and the issuance of the two million shares in this offering.  Please revise to
remove the effects of the issuance of shares in this offering and only reflect the
conversion of the preferred shares to common stock.

Exhibit 5.1

3. Refer to the registration statement fee table.  We note that you have registered the
underwriters’ warrants and the common stock underlying those warrants.  Please have
counsel revise the opinion to opine upon these  registere d securities.

You may contact Amy Geddes  at (202) 551 -3304  or Claire Erlanger  at (202) 551 -3301  if
you have questions regarding comments on the financial statements and related matters.  Please
contact Donald E. Field at (202) 551 -3680 or me at (202) 551 -3611  with any other questions.

Sincerely,

 /s/ A.N. Parker

Anne Nguyen Parker
Assistant Director
Office of Transportation and Leisure

cc: Andy Shawber
Summit Law Group

CORRESP
1
filename1.htm

October 7, 2016

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 3561

Washington, D.C. 20549-9303

    Attn.:
    Ms. Anne Nguyen Parker Assistant Director

    Office of Transportation and Leisure

    Re:
    SenesTech, Inc.

    Registration Statement on Form S-1

    Filed September 21, 2016

    File No. 333-213736

Dear Ms. Parker:

On behalf of SenesTech,
Inc. (the “Company”), we submit this letter to you in connection with comments of the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filing, received
by the Company by letter dated October 4, 2016. In this letter, we have recited the comments of the Staff set forth in the October 4,
2016 letter in italicized type, and followed each comment with the Company’s response. Simultaneously herewith, the Company
is filing with the Commission an Amendment No. 1 to Registration Statement on Form S-1 (the “Registration Statement”)
and supplementally providing, for the Staff’s review, a version of the Registration Statement marked to show changes from
the Registration Statement on Form S-1 filed with the Commission on September 21, 2016. All page numbers refer to the Registration
Statement filed simultaneously herewith.

General

Staff Comment No. 1:

1. We note your correspondence dated
September 22, 2016 related to your draft cover artwork. Please refer to page 3 and the second graphic. Please revise so that footnotes
1 through 4 are legible.

Company Response No. 1:

In response to the Staff’s comment,
enclosed herewith is the revised second graphic of the draft cover artwork, on which the footnotes 1 through 4 are included with
larger font size.

      1

Staff Comment No. 2:

2. We note from your disclosure in footnote
(2) on page F-11 that the unaudited pro forma balance sheet reflects the consideration received of $6.2 million from the shares
of stock issued in the Rights Offering as well as the repayment of $381,749 related to the Revised Note. In light of the fact that
both the receipt of cash and repayment of the Revised Note are included in the historical financial statements as of June 30, 2016,
please revise to remove this note related to the pro forma financial information. Your Capitalization table on page 30 should also
be revised to indicate that this amount is included in the historical amounts as of June 30, 2016 and should not be reflected as
a pro forma adjustment.

Company Response No. 2:

The Company has revised the Registration
Statement on pages 11, 30, 32, F-45, and F-48 to delete disclosure that indicates that such events should be included within the
pro-forma adjustments and, as appropriate, to remove the relevant note(s) related to the pro forma financial information.

Staff Comments Nos. 3, 4 and 5:

3. We note your disclosure on page 40
that pursuant to your license agreement with Neogen you earned $93,000 in revenue for each of the six months ended June 30, 2015
and 2016 due to the achievement of certain milestones and tasks under the license agreement. Please reconcile with this section
which does not reference any milestone payments. Additionally, with respect to milestone payments, please revise to disclose the
total aggregate milestone payments that may be paid under the agreement and the total aggregate milestone payments paid or received
to date.

4. We note your disclosure that pursuant
to your license agreement with Neogen you will be entitled to a license fee payable over three years following EPA approval of
ContraPest. Given your revenue stream to date, these license fees appear to be material to the company. Please revise to disclose
the total aggregate license fees that may be paid under the agreement and the total aggregate license fees paid or received to
date. In this regard, we note that certain of this information is disclosed on page F-33 in Note 14 to your financial statements.

5. We note your disclosure that pursuant
to your license agreement with Neogen you will be entitled to a semi-annual ongoing royalty based on a percentage of sales. Please
revise to disclose the potential range of royalty payments. For example, “low-single-digits,” “high-single-digits”
or a reasonable range.

Company Responses Nos. 3, 4 and 5:

The Company has revised the Registration
Statement on page 54 to disclose the requested information regarding the license agreement with Neogen.

      2

Staff Comment No. 6:

6. Please revise your balance sheet
as of December 31, 2015 and June 30, 2016 to reflect the correct total stockholders’ equity (deficit). In this regard, it
does not appear that the total stockholders’ equity (deficit) amount is the sum of the individual equity items presented
on the balance sheet.

Company Response No. 6:

The Company has revised the Registration
Statement on pages F-5, F-40 and F-42 to reflect the correct total stockholders’ equity (deficit) as of December 31, 2015
and June 30, 2016.

* * * * *

Please direct all correspondence,
notices and orders issued with respect to this matter to the undersigned. If you would like to discuss this matter by telephone,
my direct line is (206) 676-7118.

    Sincerely,

    Summit Law Group, PLLC

    a professional limited liability company

    /s/ Andrew W. Shawber

    Andrew W. Shawber

    cc:
    Loretta P. Mayer and Thomas C. Chesterman (SenesTech, Inc.)

    Laura A. Bertin

      3

      4

Mail Stop 3561
October  4, 2016

Loretta P. Mayer
Chief Executive Officer
SenesTech, Inc.
3140 N. Caden Court, Suite 1
Flagstaff, AZ  86004

Re: SenesTech, Inc.
Registration Statement on Form S-1
Filed September 21, 2016
  File No. 333 -213736

Dear Ms. Mayer :

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.

General

1. We note your correspondence dated September 22, 2016 related to your draft cover
artwork.  Please refer t o page 3  and the second graphic .  Please revise so that footnotes 1
through 4 are legible.

Summary Financial Data, page 9

2. We note from your disclosure in footnote (2) on page F -11 that the unaudited pro forma
balance sheet reflects the consideration rece ived of $6.2 million from the shares of stock
issued in the Rights Offering as well as the repayment of $381,749 related to the Revised

Loretta P. Mayer
SenesTech, Inc.
October  4, 2016
Page 2

Note.  In light of the fact that both the receipt of cash and repayment of the Revised Note
are included in the hist orical financial statements as of June 30, 2016, please revise to
remove this note related to the pro forma financial information.  Your Capitalization table
on page 30 should also be revised to indicate that this amount is included in the historical
amoun ts as of June 30, 2016 and should not be reflected as a pro forma adjustment.

Business, page 50

Neogen, page 55

3. We note your disclosure on page 40 that pursuant to your license agreement with Neogen
you earned $93,000 in revenue  for each of the six months ended June 30, 2015 and 2016
due to the achievement of certain milestones and tasks under the license agreement.
Please reconcile with this section which does not reference any milestone payments.
Additionally, w ith respect to  milestone payments, please revise to disclose the total
aggregate milestone payments that may be paid under the agreement and the total
aggregate milestone payments paid or received to date.

4. We note your disclosure that pursuant to your license agreement  with Neogen you will be
entitled to a license fee payable over three years following EPA approval of ContraPest.
Given your revenue stream to date, these license fees appear to be material to the
company.  Please revise to disclose the total aggregate li cense fees that may be paid
under the agreement and the total aggregate license fees paid or received to date.   In this
regard, we note that certain of this informati on is disclosed on page F -33 in  Note 14 to
your financial statements.

5. We note your disclo sure that pursuant to your license agreement with Neogen you will be
entitled to a semi -annual ongoing royalty based on a percentage of sales.  Please revise to
disclose the potential range of royalty payments.  For example, “low -single -digits,”
“high-single-digits” or a reasonable range .

Audited Financial Statements for the Years Ended December 31, 2014 and 2015, page F -1

6. Please revise your balance sheet as of December 31, 2015 and June 30, 2016 to reflect the
correct total stockholders’ equity (deficit) .  In this regard, it does not appear that the total
stockholders’ equity (deficit) amount is the sum of the individual equity items presented
on the balance sheet.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are  responsible for the accuracy
and adequacy of the disclosures they have made .

Loretta P. Mayer
SenesTech, Inc.
October  4, 2016
Page 3

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement, please provide  a written statement from the comp any
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any act ion with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of th e disclosure in the filing; and

 the company may not assert staff comments and th e declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may  contact Amy Geddes  at (202) 551 -3304  or Claire Erlanger  at (202) 551 -3301  if
you have questions regarding comments on the financial statements and related matters.  Please
contact Donald E. Field at (202) 551 -3680 or me at (202) 551 -3611  with any other questions.

Sincerely,

 /s/ A.N. Parker

Anne Nguyen Parker
Assistant Director
Office of Transportation and Leisure

cc: Andy Shawber
Summit Law Group

CORRESP
1
filename1.htm

September 22, 2016

The Secretary

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-9303

    Attn.:
    Ms. Anne Nguyen Parker Assistant Director

    Office of Transportation and Leisure

    Re:
    SenesTech, Inc.

    Draft Registration Statement on Form S-1

    Submitted August 3, 2016

    CIK No. 0001680378

Dear Ms. Parker:

On behalf of SenesTech,
Inc. (the “Company”), as a follow up to our letter submitted to you dated September 21, 2016, and in accordance
with our phone call with Don Field held on September 22, 2016, we submit this letter to you as an additional response to comment
No. 1 of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
regarding the above-referenced filing, which comments were received by the Company in a letter from the Staff dated August 30,
2016. Specifically, enclosed with this letter please find mock-ups of the cover artwork to be presented in the preliminary prospectus.

Please direct all correspondence,
notices and orders issued with respect to this matter to the undersigned. If you would like to discuss this matter by telephone,
my direct line is (206) 676-7118.

    Sincerely,

    Summit Law Group, PLLC

    a professional limited liability company

    /s/ Andrew W. Shawber

    Andrew W. Shawber

    cc:
    Loretta P. Mayer and Thomas C. Chesterman (SenesTech, Inc.)

    Laura A. Bertin

Enclosures.

CORRESP
1
filename1.htm

September 21, 2016

The Secretary

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-9303

Attn.:  Ms. Anne Nguyen Parker Assistant Director

           	Office of Transportation and Leisure

    Re:
    SenesTech, Inc.

    Draft Registration Statement on Form S-1

    Submitted August 3, 2016

    CIK No. 0001680378

Dear Ms. Parker:

On behalf of SenesTech,
Inc. (the “Company”), we submit this letter to you in connection with comments of the Staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) regarding the above-referenced filing, received
by the Company by letter dated August 30, 2016. In this letter, we have recited the comments of the Staff set forth in the August 30,
 2016 letter in italicized type, and followed each comment with the Company’s response. Simultaneously herewith, the
Company is filing with the Commission a Registration Statement on Form S-1 (the “Registration Statement”) and
supplementally providing, for the Staff’s review, a version of the Registration Statement marked to show changes from the
most recently filed Draft Registration Statement on Form S-1.

General

Staff Comment No. 1:

 1. Please provide us mockups of any pages that include any additional pictures or graphics to be
presented, including any accompanying captions. Please keep in mind, in scheduling your printing and distribution of the preliminary
prospectus, that we may have comments after our review of these materials.

Company Response No. 1:

We are concurrently providing the Staff with
e-mail copies of mock-ups of the cover artwork to be presented in the preliminary prospectus.

      1

Staff Comment No. 2:

 2. 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.

Company Response No. 2:

We are concurrently providing the Staff with
e-mail copies of a test the waters communication that was presented by the Company on or about March 15, 2016 to qualified institutional
buyers and/or institutional accredited investors. Note that the March 15, 2016 presentation did not include any of the content
on pages 18-22. None of the attendees were permitted to retain copies of the communications.

Staff Comment No. 3:

 3. Please update your financial statements in accordance with the provisions of Rule 8-08 of Regulation
S-X.

Company Response No. 3:

The Company has included the required updated
financial statements in the Registration Statement.

Prospectus Summary, Page 1

Staff Comment No. 4:

 4. Please revise this section to disclose that your auditors have issued a going concern opinion
on your audited financial statements. Please also disclose your net losses for the included audited periods and interim stub.

Company Response No. 4:

The Company has revised the Registration Statement
to include a new bullet point under the heading “Risk Factors” in the Prospectus Summary (page 4) to disclose that
the Company’s auditors have issued a going concern opinion on its financial statements. In addition, the Company has disclosed
the Company’s net losses for the included audited periods and interim stub in the first bullet of that section.

      2

Overview, Page 1

Staff Comment No. 5:

 5. We note your statement that you are “seeking to commercialize a proprietary technology
for managing animal pest populations.” We also note that the majority of your revenue to date has been generated from licensing
arrangements. Please revise this section to briefly discuss your commercialization plans and how you generate revenue. Additionally,
please disclose that you have not generated any revenue from product sales to date.

Company Response No. 5:

The Company has revised the Registration Statement
in accordance with the Staff’s comment. See pages 3, 17-18 and 56 of the revised Registration Statement, for example.

Staff Comment No. 6:

 6. We note your disclosure that the EPA has granted registration approval for ContraPest effective
August 2, 2016. Please revise to briefly discuss any remaining regulatory approval that is required before products sales can begin.
In this regard, we note your disclosure in the first full risk factor on page 12 that you still need applicable state approval
before ContraPest can be commercialized in the U.S. As another example, your language on page 57 with respect to “assuming
ContraPest is approved by the EPA…” implies that there is further approval required by the EPA. If known, please also
disclose the estimated costs and timing of such remaining regulatory approval.

Company Response No. 6:

The Company has revised the Registration Statement
in accordance with the Staff’s comment. See pages 1, 3, 7, 14-16, 28 and 62-65 of the revised Registration Statement, for
example.

Staff Comment No. 7:

 7. We note your statement that “the initial decline in rodent population exposed to rodenticides
is typically followed by a ‘population rebound’ as … rodents from surrounding areas migrate in.” Please
explain whether similar migration patterns may exist if a rat population were decreased through ContraPest.

Company Response No. 7:

The Company has revised the Registration Statement
in accordance with the Staff’s comment. See pages 2 and 52 of the revised Registration Statement.

      3

Staff Comment No. 8:

 8. We note the statement that “ContraPest causes rodent populations to remain at a sustained
low level, as demonstrated by studies in which we have observed decreases in wild rodent populations of more than 40%.” Please
clarify how long it took to reach the noted 40% population decrease, and how long such low level was sustained.

Company Response No. 8:

The Company has revised the Registration Statement
in accordance with the Staff’s comment. See pages 2 and 52 of the revised Registration Statement.

The Offering, Page 6

Staff Comment No. 9:

 9. Please revise the “Use of Proceeds” section here to include disclosure similar to
that included on page 26.

Company Response No. 9:

The Company has revised the Registration Statement
(page 7) in accordance with the Staff’s comment.

Risk Factors, Page 10

Staff Comment No. 10:

 10. Please revise to include a risk factor to disclose that your auditors have issued a going concern
opinion on your audited financial statements.

Company Response No. 10:

The Company has revised the Registration Statement
(page 13) in accordance with the Staff’s comment.

Use of Proceeds, Page 26

Staff Comment No. 11:

 11. Please revise to disclose the approximate amount of net proceeds that will be paid to your Series
A convertible preferred stockholders. Refer to Item 504 of Regulation S-K.

      4

Company Response No. 11:

The Company has revised the Registration Statement
in accordance with the Staff’s comment. See pages 7, 11, 28, 30, 32, 38 and F-40.

Business, Page 48

Neogen, Page 53

Staff Comment No. 12:

 12. Please revise to discuss in greater detail the license fees and royalties payable to you pursuant
to this license agreement.

Company Response No. 12:

The Company has revised the Registration Statement
(page 55) in accordance with the Staff’s comment. The Company respectfully submits that it is seeking confidential treatment
(by separate correspondence) of the specific percentages and dollar amounts payable pursuant to the Neogen license agreement.

Principal and Selling Stockholders, Page 79

Staff Comment No. 13:

 13. For The Dodge Family Enterprises, LLC and NAU Ventures, LLC, please disclose the natural persons
who have voting or investment power with respect to the shares listed in the table.

Company Response No. 13:

The Company respectfully submits that disclosure
of the beneficial ownership of the Dodge Family Enterprises, LLC is no longer required in this section as such ownership is now
less than the 5% threshold.

Report of Independent Registered Public Accounting Firm, Page
F-2

Staff Comment No. 14:

 14. We note your disclosure on page 5 that, prior to the consummation of this offering, you intend
to conduct a reverse stock split. When you determine the terms of this split, please revise your document, including the historical
financial statements and related disclosures, to give effect to this reverse split with corresponding explanatory note disclosure.
See guidance in ASC 260-10-55-12 and Staff Accounting Bulletin Topic 4C. Also, please note that this revision will prevent your
auditor from expressing an opinion on the financial statements until the split occurs. As such, please file a draft report in the
form that it will be expressed at effectiveness. This draft report should be accompanied by a signed preface of the auditor stating
that it expects to be in a position to issue the report in the form presented at effectiveness. Please note that the registration
statement cannot be declared effective until the preface is removed and the accountant’s report finalized.

      5

Company Response No. 14:

The Company has revised the Registration Statement
(page F-2) in accordance with the Staff’s comment. In addition, the Company understands that the registration statement cannot
be declared effective until the preface is removed and the accountant’s report is finalized.

Audited Financial Statements for the Years Ended December 31,
2014 and 2015, Page F-1

Staff Comment No. 15:

 15. We note your disclosure on page 26 that a portion of the proceeds of this offering will be used
to pay the holder of all of the shares of the Series A convertible preferred stock a cash payment in lieu of, and in excess of,
accrued dividends on the Series A convertible preferred stock. As it does not appear the cash payment in excess of accrued dividends
is reflected in your balance sheet, to the extent the excess is significant relative to reported equity, please revise the face
of your balance sheet to present a pro forma balance sheet alongside the historical balance sheet reflecting the distribution accrual.
Refer to SAB Topic 1B3.

Company Response No. 15:

The Company has revised the Registration Statement
in several places (see the Company’s response to Staff comment No. 11 above) to more accurately characterize the payment
to the holder of Series A convertible preferred stock, which is actually a cash payment being made pursuant to an agreement between
the parties rather than on account of accrued dividends. While the amount of the cash payment is calculated in a similar manner
to the calculation of accrued dividends (which was the calculation method agreed to by the parties), the Company agreed to make
the cash payment as consideration for the holder’s agreement to waive all accrued dividends on the Series A convertible preferred
stock and convert its shares of Series A convertible preferred stock into common stock in connection with this offering. The Company
had originally described this payment as a “cash payment in lieu and in excess of accrued dividends” when it more accurately
should have been described “as consideration for the holder’s agreement to waive all accrued dividends on the Series
A convertible preferred stock and convert its shares of Series A convertible preferred stock into common stock in connection with
this offering.” Thus, the Company respectfully submits that the nature of the payment does not give rise to a pro forma presentation.

      6

Staff Comment No. 16:

 16. As a related matter, it appears this distribution will be paid out of proceeds of the offering
rather than from current year’s earnings. As such, please present pro forma per share data on the face of the income statement
for the latest year and interim period giving effect to the number of shares whose proceeds would be necessary to pay the dividend
in addition to historical EPS. Please note the number of shares to be added to the denominator for purposes of pro forma per share
data should not exceed the total number of shares to be issued in the offering.

Company Response No. 16:

As noted in the Company’s response to
the Staff’s comment No. 15 above, the cash payment is consideration for the holder’s agreement to waive all accrued
dividends on the Series A convertible preferred stock and convert its shares of Series A convertible preferred stock into
common stock in connection with this offering. As such, the Company respectfully submits that the nature of the payment does not
give rise to a pro forma presentation.

Exhibits

Staff Comment No. 17:

 17. Please provide us with an analysis as to whether you are required to file as exhibits: your
research contract with the Chicago Transit Authority; any agreements with respect to the field trials commencing in NYC MTA, NYCHA,
Hawaii and Massachusetts (Somerville); and your exclusive license agreement with the Arizona Board of Regents of the University
of Arizona.

Company Response No. 17:

In response to the Staff’s comment, see
below for the Company’s analysis as to why it is not required to file the following items as exhibits to the Registration
Statement. In addition, we have revised the Registration Statement (page 54) to update the status of certain of these field trials.

Chicago Transit Authority:

The Company determined that the research contract
with the Chicago Transit Authority was made in the ordinary course of business for a field trial related to the effectiveness of
ContraPest and inclusion of the contract as an exhibit to the Registration Statement is not otherwise necessary for an investor’s
understanding of the Company’s relationship with Chicago Transit Authority. The Chicago Transit Authority trial is now complete
and there is no on-going commitment by either party to perform any additional services thereunder. Furthermore, the amounts involved
in the agreement are not financially material to the Company.

      7

NYC MTA:

The Company determined that the agreement with
the NYC MTA is an agreement made in the ordinary course of business for a field trial related to the effectiveness of ContraPest
and inclusion of the agreement as an exhibit to the Registration Statement is not otherwise necessary for an investor’s understanding
of the Company’s relationship with the NYC MTA. The NYC MTA trial is now complete and there is no on-going commitment by
either party to perform additional services thereunder.

NYCHA:

The Company has not yet entered into an agreement
with NYCHA regarding the ongoing field trial and the arrangement between the Company and NYCHA is made in the ordinary course of
business for contract research activities. The Company respectfully submits that inclusion of the arrangement as an exhibit to
the Registration Statement is not otherwise necessary for an investor’s understanding of the Company’s relationship
with NYHCA. Furthermore, the amounts involved in the agreement are not financially material to the Company.

Hawaii:

The Company determined that the agreement with
Hawaii is an agreement made in the ordinary course of business for contract research activities and inclusion of the agreement
as an exhibit to the Registration Statement is not otherwise necessary for an investor’s understanding of the Company’s
relationship with Hawaii. Furthermore, the amounts involved in the agreement are not financially material to the Company.

Massachusetts (Somerville):

The Company determined that the agreement with
Massachusetts (Somerville) is an agreement made in the ordinary course of business for a field trial related to the effectiveness
of ContraPest and inclusion of the agreement as an exhibit to the Registration Statement is not otherwise necessary for an investor’s
understanding of the Company’s relationship with Massachusetts (Somerville). Furthermore, the amounts involved in the agreement
have been disclosed

Mail Stop 3561
August 30, 2016

Loretta P. Mayer
Chief Executive Officer
SenesTech, Inc.
3140 N. Caden Court, Suite 1
Flagstaff, AZ  86004

Re: SenesTech, Inc.
Draft Registration Statement on Form S-1
Submitted August 3, 2016
  CIK No. 0001680378

Dear Ms. Mayer :

We have reviewed your draft 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 providing  the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is ap propriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

General

1. Please provide us mockups of any pages that include any additional pictures or graphics
to be presented, includ ing any accompanying captions.  Please keep in min d, in
scheduling your printing and distribution of the preliminary prospectus, that we may have
commen ts after our review of the se materials.

2. 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.

Loretta P. Mayer
SenesTech, Inc.
August 30, 2016
Page 2

3. Please update your financial statements in accordance with the provisions of Rule 8 -08 of
Regulation S -X.

Prospectus Summary, page 1

4. Please revise this section to disclose that your auditors have issued a going concern
opinion on your audited financial statements.  Please also disclose  your net losses for the
included  audited period s and interim stub.

Overview, page 1

5. We note your statement that you are “seeking to commercialize a proprietary technology
for managing animal pest populations.”  We also note that the majority of your revenue  to
date has been generated from licensing arrangements.  Please revise this section to briefly
discuss your commercialization plans and how you generate revenue.   Additionally,
please disclose that you have not generated any revenue from product sales to date.

6. We note your disclosure that the EPA has granted registration approval for ContraPest
effective August 2, 2016.  Please revise to briefly discuss any remaining regulatory
approval that is required before products sales can begin.  In this regard, we note your
disclosure in the first full risk factor on page 12 that you still need applicable st ate
approval before ContraPest can be commercialized in the U.S.  As another example, your
language on page 57 with respect to “ assuming ContraPest is approved by the EPA …”
implies that there is further approval required by the EPA.  If known, please also disclose
the estimated costs and timing of such remaining regulatory approval.

7. We note your statement that “ the initial decline in rodent population exposed to
rodentici des is typically followed by a ‘ population rebound ’ as … rodents from
surrounding area s migrate in .”  Please explain whether similar migration patterns may
exist if a rat population were decreased through ContraPest.

8. We note the statement that “ ContraPest causes rodent populations to remain at a
sustained low level, as demonstrated by stud ies in which we have observed decreases in
wild rodent populations of more than 40%. ”  Please clarify how long it took to reach the
noted 40% population decrease, and how long such low level was sustained.

The Offering, page 6

9. Please revise the “Use of Proceeds” section here to include disclosure similar to that
included on page 26.

Loretta P. Mayer
SenesTech, Inc.
August 30, 2016
Page 3

Risk Factors, page 10

10. Please revise to include a risk factor to disclose that your auditors have issued a going
concern opinion on you r audited financial statements.

Use of Proceeds, page 26

11. Please revise to disclose the approximate amount of net proceeds that will be paid to your
Serie s A convertible preferred stock holders.  Refer to Item 504 of Regulation S -K.

Business, page 48

Neogen, page 53

12. Please revise to di scuss in greater detail the license fees and royalties payable to you
pursuant to this license agreement.

Principal and Selling Stockholders, page 79

13. For The Dodge Family Enterprises, LLC and NAU Ventures, LLC , please disclose the
natural persons who hav e voting or investment power with respect to the shares  listed in
the table.

Report of Independent Registered Public Accounting Firm, page F -2

14. We note your disclosure on page 5 that, prior to the consummation of this offering, you
intend to conduct a reverse stock split.  When you determine the terms of this split, please
revise your document, including the historical financial statements and related
disclosures, to  give effect to this reverse split with corresponding explanatory note
disclosure.  See guidance  in ASC 260 -10-55-12 and Staff Accounting Bulletin Topic 4C.
Also, please note that this  revision will prevent your auditor from expressing an opinion
on the financial statements  until the split occurs.  As such, please file a draft r eport in the
form that it will be expressed  at effectiveness.  This draft report should be accompanied
by a signed preface of the auditor  stating that it expects to be in a position to issue the
report in the form presented at  effectiveness.  Please note t hat the registration statement
cannot be declared effective until the  preface is removed and the accountant’s report
finalized.

Loretta P. Mayer
SenesTech, Inc.
August 30, 2016
Page 4

Audited Financial Statements for the Years Ended December 31, 2014 and 2015, page F -1

15. We note your disclosure on page 26  that a portion of the proceeds of this offering will be
used to pay the holder of all of the shares of the Series A convertible preferred stock a
cash payment in lieu of, and in excess of, accrued dividends on the Series A convertible
preferred  stock.  As it does not appear the cash payment in excess of accrued dividends is
reflected in  your balance sheet, to the extent the excess is significant relative to reported
equity, please  revise the face of your balance sheet to present a pro  forma balance sheet
alongside the  historical balance sheet reflecting the distribution accrual.  Refer to SAB
Topic 1B3.

16. As a related matter, it appears this distribution will be paid out of proceeds of the offering
rather than from current year’s earnings.  As such, please p resent pro forma per share
data on  the face of the income statement for the latest year and interim period giving
effect to the  number of shares whose proceeds would be necessary to pay the dividend in
addition to  historical EPS.  Please note the number of  shares to be added to the
denominator for purposes  of pro forma per share data should not exceed the total number
of shares to be issued in the  offering.

Exhibits

17. Please provide us with an analysis as to whether you are required to file as exhibits:  yo ur
research contract with the Chicago Transit Authority ; any agreements with respect to the
field trials commencing in NYC MTA, NYCHA, Hawaii and Massachusetts
(Somerville) ; and your exclusive license agreement with the Arizona Board of Regents of
the Univ ersity of Arizona .

You may contact Amy Geddes  at (202) 551 -3304  or Claire Erlanger  at (202) 551 -3301  if
you have questions regarding comments on the financial statements and related matters.  Please
contact Donald E. Field at (202) 551 -3680 or me at (202)  551-3611  with any other questions.

Sincerely,

 /s/ A.N. Parker

Anne Nguyen Parker
Assistant Director
Office of Transportation and Leisure

cc: Andy Shawber
Summit Law Group