May 18, 2023

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. 333-269083

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 take appropriate action to cause the above-referenced Registration Statement on Form S-1, as amended, to become effective as of 5:00 p.m. (Eastern time) on Monday, May 22, 2023, 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