Exhibit 51

Exhibit 5.1

Fennemore Craig, P.C.
300 E. Second Street

Suite 1510

Reno, Nevada 89501

(775) 788-2200

Law Offices

Denver(303) 291-3200

Las Vegas(702) 692-8000

Nogales(520) 281-3480

Phoenix(602) 916-5000

Reno(775) 788-2200

Tucson(520) 879-6800

March 23, 2017

Pulse Biosciences, Inc.

849 Mitten Road, Suite 104

Burlingame, CA 94010

Re:Registration of Common Stock of Pulse Biosciences, Inc.

Ladies and Gentlemen:

We are acting as special Nevada counsel for Pulse Biosciences, Inc., a Nevada corporation (the "Company"), in connection with the registration under a Registration Statement on Form S-8 (the "Registration Statement") by the Company under the Securities Act of 1933, as amended (the "Act"), of 1,433,838 shares of common stock, par value $.001 per share of the Company (“Common Stock”) consisting of (i) 208,248 shares of Common Stock that may be issued by the Company pursuant to the Company’s 2015 Stock Incentive Plan (the “2015 Plan”); (ii) 922,970 shares of Common Stock that may be issued by the Company pursuant to equity awards outstanding under the 2015 Plan (all such shares of Common Stock that may be issued pursuant to the 2015 Plan, the “Plan Shares”); (iii) 75,665 shares of Common Stock that may be issued pursuant to the Pulse Biosciences, Inc. Stock Option Agreement dated February 1, 2015 between the Company and Robert M. Levande; (iv) 75,665 shares of Common Stock that may be issued pursuant to the Pulse Biosciences, Inc. Stock Option Agreement dated February 1, 2015 between the Company and Mitchell E. Levinson; (v) 75,665 shares of Common Stock that may be issued pursuant to the Pulse Biosciences, Inc. Stock Option Agreement dated February 1, 2015 between the Company and Robert J. Greenberg; and (vi) 75,665 shares of Common Stock that may be issued pursuant to the Pulse Biosciences, Inc. Stock Option Agreement dated June 16, 2015, between the Company and Thierry Thaure (all shares of Common Stock referred to in Sections (iii) through (vi) of this paragraph, the “Option Shares” and the foregoing Stock Option Agreements, collectively, the “Option Agreements”)).

We have examined originals or copies of each of the documents listed below:

1.The Amended and Restated Articles of Incorporation of the Company, as amended, as certified by an officer of the Company as of the date hereof;

Fennemore Craig, P.C.

Pulse Biosciences, Inc.

Re:Registration of Common Stock

March 23, 2017

Page 2

2.The Amended and Restated Bylaws of the Company, as certified by an officer of the Company as of the date hereof;

3.Resolutions of the Board of Directors of the Company relating to the 2015 Plan and each of the Stock Option Agreements referred to in Section (iii) through (vi) of the first paragraph of this opinion letter, as certified by an officer of the Company as of the date hereof;

4.The Option Agreements.

5.The 2015 Plan.

6.The Registration Statement.

We have examined originals or copies of such other corporate records, certificates of corporate officers and public officials and other agreements and documents as we have deemed necessary or advisable for purposes of this opinion letter. We have relied upon the certificates of all public officials and corporate officers with respect to the accuracy of all factual matters contained therein.

Without limiting the generality of the foregoing, in our examination, we have, with your permission, assumed without independent verification, that (i) all documents submitted to us as originals are authentic, the signatures on all documents that we examined are genuine, and all documents submitted to us as certified, conformed, photostatic, electronic or facsimile copies conform to the original document; (ii) all corporate records made available to us by the Company and all public records we have reviewed are accurate and complete; and (iii) at the time the shares of Common Stock being registered under the Registration Statement are issued, there will be sufficient authorized but unissued Common Stock available to allow for such issuance.

Based upon the foregoing, and subject to the following, it is our opinion that:

1.Issuance of the Plan Shares has been duly authorized by the Company and, when issued upon conversion in accordance with the terms of the 2015 Plan, the Plan Shares will be validly issued, fully paid and nonassessable.

2.Issuance of the Option Shares has been duly authorized by the Company and, when issued in accordance with the terms of the respective Stock Option Agreement, the Option Shares will be validly issued, fully paid and nonassessable.

12691278

Fennemore Craig, P.C.

Pulse Biosciences, Inc.

Re:Registration of Common Stock

March 23, 2017

Page 3

The opinions expressed above are limited to the laws of the State of Nevada, including reported judicial decisions.

This opinion is issued in the State of Nevada. By issuing this opinion, Fennemore Craig, P.C. (i) shall not be deemed to be transacting business in any other state or jurisdiction other than the State of Nevada and (ii) does not consent to the jurisdiction of any state other than the State of Nevada. Any claim or cause of action arising out of the opinions expressed herein must be brought in the State of Nevada. Your acceptance of this opinion shall constitute your agreement to the foregoing.

We consent to your filing of this opinion as an exhibit to the Registration Statement and further consent to the use of our name wherever appearing in the Registration Statement. We further consent to the incorporation by reference of this opinion and consent in any registration statement filed pursuant to Rule 462(b) under the Act with respect to the Common Stock. In giving these consents, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Act, the rules and regulations of the Securities and Exchange Commission promulgated thereunder, or Item 509 of Regulation S-K. This opinion letter is rendered as of the date first written above and we disclaim any obligation to advise you of facts, circumstances, events or developments which hereafter may be brought to our attention and which may alter, affect or modify the opinion expressed herein. Our opinion is expressly limited to the matters set forth above and we render no opinion, whether by implication or otherwise, as to any other matters relating to the Company or the Common Stock.

Very truly yours,

/s/ Fennemore Craig, P.C.

Fennemore Craig, P.C.

12691278