B. Riley Securities, Inc.

299 Park Avenue, 21^st Floor

New York, NY 10171

September 26, 2023

Via EDGAR

Division of Corporation Finance

Securities and Exchange Commission
100 F Street, N.E.

Washington, D.C. 20549
Attention: Madeleine Mateo, Attorney Advisor

RE:	SWK Holdings Corporation
	Registration Statement on Form S-1
	File No. 333-274511
	Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), we hereby join in the request of SWK Holdings Corporation for acceleration of the effective date of the above-referenced Registration Statement, as then amended, so that it may become effective at 4:30 p.m., Eastern time, on September 28, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 of the Act, we wish to advise you that the underwriters have distributed as many copies of the Preliminary Prospectus, dated September 26, 2023 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

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

If you have any questions regarding this request, please call Dean M. Colucci of Duane Morris LLP at (973) 424-2020.

Very truly yours,
B. RILEY SECURITIES, INC., as representative of the several underwriters
By:	/s/ Patrice McNicoll
Name:	Patrice McNicoll
Title:	Co-Head of Investment Banking

cc: Daniel Palmadesso, Vice President & Assistant General Counsel at B. Riley Financial and Dean M. Colucci, Duane Morris LLP