April 20, 2022

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Gary Guttenberg

Re:	Aclarion, Inc.
	Registration Statement on Form S-1 (File No. 333-262026)

Ladies and Gentlemen:

As the underwriter of the proposed offering of Aclarion, Inc. (the “Company”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 5:00 p.m., Eastern Time, on April 21, 2022, or as soon thereafter as is practicable. 

Pursuant to Rule 460 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, we, acting on behalf of the several underwriters, wish to advise you that, through April 19, 2022, we distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many copies, as well as “E-red” copies of the Preliminary Prospectus dated April 1, 2022, as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. 

Very truly yours,
Maxim Group LLC
By:	/s/ Clifford A. Teller
	Name: Clifford A. Teller Title: Head of Investment Banking, Executive Managing Director