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                             May 25, 2022

       Sandra Gardiner
       Chief Financial Officer, Executive Vice President and Treasurer
       Pulse Biosciences, Inc.
       3957 Point Eden Way
       Hayward, California 94545

                                                        Re: Pulse Biosciences,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed March 31,
2022
                                                            File No. 001-37744

       Dear Ms. Gardiner:

              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 business days by
providing the requested
       information or advise us as soon as possible when you will respond. 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 the Fiscal Year Ended December 31, 2021

       Notes to the Consolidated Financial Statements
       9. Revenue
       Performance Obligations, page 86

   1.                                                   You state that the
Cycle Units (CUs) are credits that authorize the customer to perform a
                                                        procedure and that each
procedure requires a specific number of CUs. Once the CUs are
                                                        reduced to zero, the
customer is required to purchase additional CUs to perform additional
                                                        procedures. Please
address the following with regard to your revenue recognition policy
                                                        for your Cycle Units:
                                                            Tell us, and
clarify in future filings, if the CUs are bundled together into a single
                                                             performance
obligation when you record the initial sale of the CellFX System
                                                             pursuant to ASC
606-10-25-22. If such is the case, please tell us why recognition at a
                                                             point in time for
the sale is appropriate given the CUs are utilized over time and the
                                                             System cannot be
used without the CUs. Refer to ASC 606-10-25-27. In your
 Sandra Gardiner
FirstName  LastNameSandra  Gardiner
Pulse Biosciences, Inc.
Comapany
May        NamePulse Biosciences, Inc.
     25, 2022
May 25,
Page 2 2022 Page 2
FirstName LastName
              analysis, please distinguish your accounting treatment between
sales of the CellFX
              Systems in and outside the Controlled Launch Program.
                Tell us your basis for concluding the CUs represent a "good"
vs. a "service" (e.g. not
              accompanied by subsequent Pulse Bio consultation regarding CUs
necessary for a
              novel dermatological procedure). Tell us the nature/form of the
CUs, how they are
              delivered to the customer and how unused CUs are stored.
                For sales of additional CUs outside the initial sale of the
CellFX System, tell us, and
              clarify in future filings, why immediate revenue recognition at a
point in time is
              appropriate upon delivery to the CellFX CloudConnect given the
performance
              obligation does not appear to have been met until the customer
redeems the CU upon
              performing a procedure.
Transaction Price, page 86

2.       Disclose how you determine the transaction price. Refer to ASC
606-10-50-20.
Controlled Launch Agreements, page 87

3.       You state on page 85 that as patient procedures and surveys are
completed under the
         Controlled Launch, you accrue the value of credits earned by the
participants in accrued
         expenses with a corresponding charge to sales and marketing expense.
You state on page
         55 that the majority of your revenue for the year-ended December 31,
2021 was
         recognized on a non-cash basis when Controlled Launch Program
participants applied
         their earned credits towards the purchase of a CellFX System. You
disaggregate your
         revenue on page 87 of the 10-K by product and disclose on page 85 the
amount of the
         accrued liability related to the Controlled Launch that was relieved
and recognized as
         revenue on a non-cash basis. Please address the following:
             Provide us an analysis of the basis for your accounting treatment
for the earned
              credits.
                o   Help us understand your basis for recognizing revenue on
the sale of the CellFX
                    System that in substance has been provided
"free-of-charge".
                o   Tell us your accounting treatment and the basis thereof for
relieving the accrued
                    expenses for CellFX Systems included in the Controlled
Launch Program.
                    Separately discuss when the accrued expenses are relieved
for a sale and for
                    which a sale is not ultimately consummated.
                o   Tell us the basis for initially recording the earned
credits as sales and marketing
                    expenses. In this regard, we note on page 5 that you are
expanding your clinical
                    studies to broaden the approved uses of the CellFX System.
Reference key
                    terms in the contractual arrangements with the physicians
and practices that
                    support your accounting as sales and marketing expense.
             Confirm that the customer has title to the CellFX System upon
consummation of the
              sale transaction. If the CellFX System may revert back to the
company, tell us your
              consideration of recording the portion of the sale relating to
the System as a lease
              pursuant to ASC 842.
 Sandra Gardiner
Pulse Biosciences, Inc.
May 25, 2022
Page 3
                Notwithstanding the above, tell us why you believe recognizing
the revenue recorded
              on a non-cash basis in the same line item on the Statement of
Operations as revenue
              earned on a cash basis is appropriate.
                Tell us why the presentation of relieving the accrued expenses
as Revenue is
              appropriate when the cost of revenue was previously recorded as
sales and marketing
              expense. In addition, we note that revenue is being recorded
without a related cost of
              sales.
                Cite any applicable guidance you used in determining the
accounting treatment.

       In closing, 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 Frank Wyman at 202-551-3660 or Mary Mast at 202-551-3613
with
any questions.



FirstName LastNameSandra Gardiner                              Sincerely,
Comapany NamePulse Biosciences, Inc.
                                                               Division of
Corporation Finance
May 25, 2022 Page 3                                            Office of Life
Sciences
FirstName LastName