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                          November 29, 2022

       Charles D. Goodwin II
       Chief Executive Officer
       Apyx Medical Corp.
       5115 Ulmerton Road
       Clearwater, FL 33760

                                                        Re: Apyx Medical Corp.
                                                            Registration
Statement on Form S-3
                                                            Filed November 22,
2022
                                                            File No. 333-268532

       Dear Charles D. Goodwin II:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Benjamin
Richie at 202-551-7857 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Industrial Applications and

                          Services
       cc:                                              Adam P. Silvers, Esq.