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                             May 29, 2024

       Steven Foster
       Chief Executive Officer and President
       Tenon Medical, Inc.
       104 Cooper Court
       Los Gatos, CA 95032

                                                        Re: Tenon Medical, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed May 10, 2024
                                                            File No. 333-279336

       Dear Steven Foster:

              We have conducted a limited review of your registration statement
and have the
       following comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a 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 letter, we may have additional comments.

       Registration Statement on Form S-1 filed May 10, 2024

       The Lincoln Park Transaction, page 48

   1.                                                   We note your disclosure
here that you registered 598,909 shares of your common stock
                                                        under your original
registration statement. The registration statement on Form S-1 (File
                                                        No. 333-274451) that
was declared effective on September 21, 2023, registered 5,989,087
                                                        Shares of Common Stock.
Please revise to clarify the reason for this apparent
                                                        inconsistency. For
example, if it relates to the November 2023 reverse stock split, please
                                                        revise to describe the
effect of the stock split on the initial number of shares registered
                                                        under the prior
registration statement, or otherwise explain why these numbers do not
                                                        correspond.
       General

   2.                                                   We note that you are
seeking to register 5,014,654 shares of your common stock for resale
                                                        by the selling
stockholder Lincoln Park Capital Fund, LLC pursuant to the Purchase
 Steven Foster
Tenon Medical, Inc.
May 29, 2024
Page 2
       Agreement between you and Lincoln Park Capital Fund, LLC dated as of
July 24, 2023.
       We also note the effected reverse stock split that took place on
November 2, 2023.
       However, it appears that you have registered some or all of these
securities under the
       Registration Statement on Form S-1 (File No. 333-274451) declared
effective by the SEC
       on September 21, 2023. Please clarify what portion of these securities
have been
       registered, and provide us your analysis regarding why it is appropriate
to register what
       appear to be the same securities on this registration statement, or
remove these shares
       from your registration statement. We note your disclosure that you may
elect to issue and
       sell to Lincoln Park Capital Fund, LLC more than the 5,000,000 shares of
common stock
       reserved under the Purchase Agreement. To the extent that these shares
are in addition to
       the 5,000,000 shares registered on the Form S-1 in September 2023
pursuant to the
       Purchase Agreement, then please revise disclosure throughout the
registration statement to
       reflect that the shares being registered under this registration
statement are outside of the
       reserved amount pursuant to the Purchase Agreement with Lincoln Park
Capital Fund,
       LLC
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Nicholas O'Leary at 202-551-4451 or Abby Adams at
202-551-6902 with
any other questions.



                                                             Sincerely,

FirstName LastNameSteven Foster                              Division of
Corporation Finance
                                                             Office of
Industrial Applications and
Comapany NameTenon Medical, Inc.
                                                             Services
May 29, 2024 Page 2
cc:       Jeffrey P. Wofford, Esq.
FirstName LastName