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                           May 14, 2024

       Fredrik Nihl  n
       Interim Chief Executive Officer
       Neonode Inc.
       2880 Zanker Rd.
       San Jose, CA, 95134

                                                        Re: Neonode Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed May 9, 2024
                                                            File No. 333-279252

       Dear Fredrik Nihl  n:

              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 Patrick
Fullem at 202-551-8337 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Manufacturing
       cc:                                              Michael S. Lee, Esq.