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                               February 1, 2023

       Brian Carrico
       Chief Executive Officer
       Neuraxis, Inc.
       11550 N. Meridian Street, Suite 325
       Carmel, IN 46032

                                                        Re: Neuraxis, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed January 26,
2023
                                                            File No. 333-269179

       Dear Brian Carrico:

              We have reviewed your amended registration statement and have the
following
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
January 24, 2023 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed January 26,
2023

       Risk Factors
       Volatility in the market price of our common stock may prevent
investors..., page 35

   1.                                                   We note your discussion
of stock price volatility in relation to early-stage companies at
                                                        the bottom of page 35.
Please move this discussion to a separately titled risk factor and
                                                        revise to also discuss
known factors particular to the offering and the company that may
                                                        add to the volatility
risk discussed. For example, if the company will have a relatively low
                                                        public float after the
offering, risks surrounding lack of trading, liquidity and market price
                                                        related to such low
public float should be addressed.
 Brian Carrico
Neuraxis, Inc.
February 1, 2023
Page 2

       You may contact Gary Newberry at 202-551-3761 or Lynn Dicker at
202-551-3616 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cindy Polynice at 202-551-8707 or Laura Crotty at 202-551-7614 with any
other
questions.



                                                          Sincerely,
FirstName LastNameBrian Carrico
                                                          Division of
Corporation Finance
Comapany NameNeuraxis, Inc.
                                                          Office of Life
Sciences
February 1, 2023 Page 2
cc:       Tom Twedt
FirstName LastName