United States securities and exchange commission logo





                          September 21, 2020

       David Evans
       Interim Chief Executive Officer
       Guardion Health Sciences, Inc.
       15150 Avenue of Science, Suite 200
       San Diego, California 92128

                                                        Re: Guardion Health
Sciences, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed September 18,
2020
                                                            File No. 333-248895

       Dear Mr. Evans:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Tim
Buchmiller at (202) 551-3635 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences
       cc:                                              David I. Sunkin, Esq.