Mail Stop 3030

                                                                June 13, 2018

     Kevin A. Richardson, II
     Acting Chief Executive Officer
     SANUWAVE Health, Inc.
     3360 Martin Farm Road, Suite 100
     Suwanee, Georgia 30024

            Re:    SANUWAVE Health, Inc.
                   Amendment No. 5 to Registration Statement on Form S-1
                   Filed May 25, 2018
                   File No. 333-213774

     Dear Mr. Richardson:

            We have limited our review of your amended registration statement
to those issues we
     have addressed in our comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments.
Unless we note
     otherwise, our references to prior comments are to comments in our March
12, 2018 letter.

     Calculation of Registration Fee

     1.     Your footnote 2 to the fee table indicates that the 52,086,297
shares of common stock
            represent the resale of shares of common stock issuable upon
exercise of warrants issued
            to the selling stockholders whereas your disclosure on the
prospectus cover page and on
            page 2 indicates that these are outstanding shares of common stock
held by the selling
            shareholders. Please advise or revise.

     2.     It appears that 23,545,114 shares of commons stock being registered
for resale in your
            current amendment are also currently registered for resale in your
registration statement
            that was declared effective February 16, 2016. Similarly, we note
from your response to
            prior comment 3 that the shares offered for resale in your
registration statement on
            Form S-1 file number 333-195263 are concurrently intended to be
offered for resale in
 Kevin A. Richardson, II
SANUWAVE Health, Inc.
June 13, 2018
Page 2

       this registration statement. Please tell us the legal authority upon
which you rely to have
       the same securities offered for resale by the prior registration
statements offered by your
       pending registration statement. Please advise, citing any legal
authority upon which you
       rely, or revise.

Description of Transactions and Relationships Between the Company and the
Selling
Stockholders within the Past Three Years, page 20

3.     Your disclosure in this section regarding the shares being registered
for resale by the
       selling stockholders does not reconcile to the 111,215,484 indicated in
your fee table or at
       the end of your table on page 25. Please advise or revise.

       Please contact Tim Buchmiller at (202) 551-3635 or me at (202) 551-3412
with any
questions.


                                                            Sincerely,

                                                            /s/ Amanda Ravitz

                                                            Amanda Ravitz
                                                            Assistant Director
                                                            Office of
Electronics and Machinery


cc:    John C. Ethridge, Jr., Esq.
       Smith, Gambrell & Russell, LLP