United States securities and exchange commission logo

                            October 27, 2021

       Thomas Higgins
       Senior Vice President, Chief Financial Officer and Treasurer
       NeuroMetrix, Inc.
       4B Gill Street
       Woburn, Massachusetts 01801

                                                        Re: NeuroMetrix, Inc.
Statement on Form S-3
                                                            Filed on October
22, 2021
                                                            File No. 333-260438

       Dear Mr. Higgins:

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

               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 Jessica
Ansart at (202) 551-4511 with any questions.


                            Division of Corporation Finance

                            Office of Life Sciences
       cc:                                              Megan Gates