TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo September 21, 2023 Jody Staggs Chief Executive Officer SWK Holdings Corporation 5956 Sherry Lane, Suite 650 Dallas, TX 75225 Re: SWK Holdings Corporation Registration Statement on Form S-1 Filed September 14, 2023 File No. 333-274511 Dear Jody Staggs: 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 Madeleine Mateo at 202-551-3465 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Justin Platt, Esq.