February 8, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: NovaBay Pharmaceuticals, Inc. (the “Company”) Form S-1, File No. 333-262550

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the Company hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form S-1 to become effective as of 5:00 p.m. (Eastern time) on Thursday, February 10, 2022, or as soon as practicable thereafter.

		Very truly yours,
		NovaBay Pharmaceuticals, Inc.
		By:	/s/ Justin Hall
			Justin Hall
			Chief Executive Officer and General Counsel
cc:	Abby E. Brown, Squire Patton Boggs (US) LLP