December 17, 2019

Liangjian Peng
Chief Executive Officer
Hypertension Diagnostics, Inc.
550 Highway 7 East, Unit 316
Minneapolis, MN 55402

       Re: Hypertension Diagnostics, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed September 18, 2019
           File No. 000-24635

Dear Mr. Peng:

         Our initial review of your Form 10-K for the year ended December 31,
2018 indicates
that it fails in numerous material respects to comply with the requirements of
the Securities
Exchange Act of 1934, the rules and regulations thereunder and the requirements
of Form 10-K.

Form 10-K for the Fiscal Year Ended December 31, 2018

General

1.    Please amend your filing to include the information required by Parts I
through IV of
      Form 10-K. For example:

           You have not provided a description of your business or any risk
factors as required
           by Items 1 and 1A of Part I.
           You have not provided management's discussion and analysis of
financial condition
           and results of operations as required by Item 7 of Part II.
           While you have included certain financial statements, they have not
been audited by a
           PCAOB-registered firm and do not comply with Item 8 of Part II.
Furthermore, they
           do not comply with Article 8 of Regulation S-X.
           You have provided Item 9A. of Form 10-K but fail to comply with its
requirements,
           including the following:
             o  You failed to provide a conclusion as to the effectiveness of
disclosure controls
                and procedures and internal control over financial reporting as
required by Items
                307 and 308 of Regulation S-K.
             o  You list Liangjian Peng as your Chief Executive Officer who
also signed your
                Form 10-K. However, Item 9A. Controls and Procedures discloses
that Kenneth
                Brimmer is your CEO. It is unclear how Kenneth Brimmer is still
affiliated
 Liangjian Peng
Hypertension Diagnostics, Inc.
December 17, 2019
Page 2

                  with your company and why he is referenced in your filing.
              You did not provide the certifications required by Sections 302
and 906 of the
              Sarbanes-Oxley Act of 2002.

         Similarly, you should amend your Form 10-K for the year ended December
31, 2017 and
         your quarterly reports for each of the quarters ended 2019 to comply
with the
         requirements of each form. Please respond to this 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 this comment, we may have additional
comments.

       In closing, 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.

      You may contact Li Xiao, Staff Accountant, at (202) 551-4391 or Brian
Cascio,
Accounting Branch Chief, at (202) 551-3676 with any questions.



FirstName LastNameLiangjian Peng                              Sincerely,
Comapany NameHypertension Diagnostics, Inc.
                                                              Division of
Corporation Finance
December 17, 2019 Page 2                                      Office of Life
Sciences
FirstName LastName