Mail Stop 3030
                                                                 July 13, 2018


     Via E-mail
     Dean Irwin
     Chief Executive Officer
     Ra Medical Systems, Inc.
     2070 Las Palmas Drive
     Carlsbad, CA 92011

            Re:     Ra Medical Systems, Inc.
                    Amendment No. 1 to
                    Draft Registration Statement on Form S-1
                    Submitted June 28, 2018
                    CIK No. 0001716621

     Dear Mr. Irwin:

           We have reviewed your amended draft registration statement 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 providing the requested
information and either submitting
     an amended draft registration statement or publicly filing your
registration statement on
     EDGAR. 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 the information you provide in response to these
comments and your
     amended draft registration statement or filed registration statement, we
may have additional
     comments.

     Overview, page 1

     1.     We note your response to comment 12. Please expand your response to
clarify whether
            your intended future DABRA uses, as disclosed in the fourth
sentence, will similarly
            address the results of vascular diseases or the vascular diseases
themselves.

     Strengths of our Approach   DABRA, page 3

     2.     Expand your response to comment 4 to address other technical terms
the first time they
            are used, such as dissection or perforation.
 Dean Irwin
Ra Medical Systems, Inc.
July 13, 2018
Page 2

We face credit and compliance risk..., page 22

3.     Please expand your response to comment 8 to discuss any relevant details
about your
       distributors' location or advise why you do not believe such information
is material to an
       investor's assessment of the risk you describe.

Results of Operations, page 75

4.     We note your decrease in direct unit sales in your Dermatology segment
for the period
       ended March 31, 2018 compared to March 31, 2017 and your offsetting
increase in
       income from rentals of your laser products. Please tell us whether a
shift exists towards
       rentals from product purchases and, if so, whether that shift reflects a
material trend that
       must be discussed per Regulation S-K Item 303.

Reimbursement, page 102

5.     We note your response to comments 1 and 7 and removed disclosure
previously made in
       the third sentence of this section's second paragraph. Tell us whether
your customers'
       purchases or rentals of your laser products are reimbursable by
third-party payors as a
       portion of the reimbursement of the procedure, and if not, revise to
further clarify how
       this lack of reimbursement would impact your products' marketability.

Note 3   Restatement and reclassification, page F-15

6.     We note your response to comment 28. To enhance an investor's
understanding of the
       restatement, if true, please revise the third sentence of the first
bullet on page F-15 to
       clarify your conclusion that the awards are required to be classified as
liabilities
       remeasured at each reporting date, rather than as "equity-classified"
option awards as
       previously reported.

Item 15. Recent Sales of Unregistered Securities, page II-2

7.     Expand your response to comment 29 to provide more information
concerning the
       "investors" disclosed in paragraphs (a) and (c). Your revised disclosure
should provide
       sufficient information to demonstrate the applicability of the
exemptions claimed in the
       paragraph following paragraph (c).
 Dean Irwin
Ra Medical Systems, Inc.
July 13, 2018
Page 3

        You may contact Eric Atallah at (202) 551-3663 or Kevin Kuhar,
Accounting Branch
Chief, at (202) 551-3662 if you have questions regarding comments on the
financial statements
and related matters. Please contact Caleb French at (202) 551-6947 or Heather
Percival, Senior
Attorney, at (202) 551-3498 with any other questions.


                                                          Sincerely,

                                                          /s/ Heather Percival
for

                                                          Amanda Ravitz
                                                          Assistant Director
                                                          Office of Electronics
and Machinery

cc:    Martin J. Waters, Esq.
       Wilson Sonsini Goodrich & Rosati, P.C.