UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                              WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                               November 19,
2018

  By E-Mail

  Andrew D. Hudders, Esq.
  Golenbock Eiseman Assor Bell & Peskoe LLP
  711 Third Avenue   17th Floor
  New York, NY 10022

          Re:     ClearSign Combustion Corporation
                  Preliminary Proxy Statement filed Anthony DiGiandomenico
                  Filed on November 9, 2018
                  File No. 001-35521

  Dear Mr. Hudders:

        We have reviewed your filing and have the following 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 filing, by providing
the requested
  information, or by advising us when you will provide the requested response.
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 filing and the information you
provide in
  response to these comments, we may have additional comments.

  Preliminary Proxy Statement

  1.      Please provide us your analysis of whether MDB Capital Group LLC and
Richard
          Deutsch are participants in your solicitation. See Instruction 3 to
Item 4 of Schedule 14A
          for guidance.

  2.      Each statement or assertion of opinion or belief must be clearly
characterized as such,
          and a reasonable factual basis must exist for each such opinion or
belief. Support for
          opinions or beliefs should be self-evident, disclosed in the proxy
statement or provided to
          the staff on a supplemental basis. Provide support for your statement
that "...the
          company has been underperforming and is not taking advantage of its
resources and
          opportunities under the current Board and management."

  3.      Please clarify on page 2 the meaning of "ineffective pursuit of
business opportunities."
 Andrew D. Hudders, Esq.
Golenbock Eiseman Assor Bell & Peskoe LLP
November 19, 2018
Page 2

4.     Revise your disclosure to generally address whether the replacement of
all or a majority
       of the current directors would have a negative effect on the company.
For example,
       describe whether any members of management would be entitled to receive
       compensation under any change of control agreement or similar provision
in an
       employment agreement and whether any company obligation would be
accelerated.++

5.     With respect to the first full paragraph on page 3, please revise your
disclosure to explain
       whether you are entitled to revise the proposals for an eventual special
meeting under
       Washington law. We may have further comment.

6.     Refer to the fifth full paragraph on page 3. With a view towards revised
disclosure, tell us
       how you are "sure that the Company will try to say that [you] will not
have the full
       percentage of votes to call a meeting if [you deliver] less than 25% but
more than 10%."
       You must avoid issuing statements that directly or indirectly impugn the
character,
       integrity or personal reputation or make charges of illegal, improper or
immoral conduct
       without factual foundation. In this regard, note that the factual
foundation for such
       assertion must be reasonable. Refer to Rule 14a-9.

7.     Please tell us the Washington state law that provides for consents to be
delivered within
       seventy (70) days of the record date.

Past Contacts, page 5

8.     Please provide us supplemental support regarding Mr. Tokman's business
       accomplishments (first full paragraph of page 6) and regarding the email
Mr. Bell sent to
       Mr. DiGiandomenico on October 4, 2018 (second full paragraph of page 6).

Written Request Procedures, page 8

9.     Please tell us the authority upon which you based your disclosure that
the proxies may
       use their proxy authority to apply for a court order that the special
meeting be held.

Certain Information Regarding the Solicitation Participant, page 10

10.    We note your disclosure in the last paragraph on page 10. With a view
toward revised
       disclosure, please tell us whether the company paid compensation in
excess of $120,000
       to MDB Capital Group, since the beginning of the registrant's last
fiscal year, and
       whether MDB Capital Group is an associate of Mr. DiGiandomenico.

Schedule II, page 14

11.    Please update this disclosure.
 Andrew D. Hudders, Esq.
Golenbock Eiseman Assor Bell & Peskoe LLP
November 19, 2018
Page 3

Form of Proxy Card

12.    Given that the solicitation relates solely to the calling of a special
meeting, tell us why
       you have included the five proposals you may present at an eventual
special meeting in
       the proxy card.

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff

       Please direct any questions to me at (202) 551-3619.

                                                             Sincerely,

                                                             /s/ Daniel F.
Duchovny
                                                             Daniel F. Duchovny
                                                             Special Counsel
                                                             Office of Mergers
and Acquisitions