October 25, 2019

Michael Favish
Chief Executive Officer
Guardion Health Sciences, Inc.
15150 Avenue of Science, Suite 200
San Diego, CA 92128

       Re: Guardion Health Sciences, Inc.
           Preliminary Proxy Statement on Schedule 14A
           Filed October 18, 2019
           File No. 001-38861

Dear Mr. Favish:

       We have reviewed your filing and have the following comment.

       Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A

Proposal 3: Amendment of Certificate of Incorporation to increase Number of
Authorized
Common Stock, page 18

1.    Please revise the proxy statement to indicate whether you currently have
any plans,
      arrangements or understandings, written or oral, to issue any of the
authorized but
      unissued shares that would become available as a result of the charter
amendment.

        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.
 Michael Favish
Guardion Health Sciences, Inc.
October 25, 2019
Page 2

        You may contact Joseph McCann at (202) 551-6262 or Mary Beth Breslin,
Legal Branch
Chief, at (202) 551-3625 if you have questions.



                                                        Sincerely,
FirstName LastNameMichael Favish
                                                        Division of Corporation
Finance
Comapany NameGuardion Health Sciences, Inc.
                                                        Office of Life Sciences
October 25, 2019 Page 2
cc:       David Sunkin
FirstName LastName