December 12, 2018

Jennifer K. Simpson, Ph.D.
President and Chief Executive Officer
Delcath Systems, Inc.
1633 Broadway Suite 22C
New York, NY 10019

       Re: Delcath Systems, Inc.
           Amendment No. 1 to Registration Statement on Form S-3
           Filed November 30, 2018
           File No. 333-227970

Dear Dr. Simpson:

       We have limited our review of your amended registration statement to
those issues we
have addressed in our 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our November 19,
2018 letter.

Form S-3 Amended November 30, 2018

Incorporation by Reference, page 2

1.     We note your response to prior comment 2. Please list all documents that
satisfy the
       criteria mentioned in the last clause of your fourth bullet point in
this section.

Risk Factors, page 5

2.     Please expand your response to prior comment 1 to tell us where the
offer of the shares
       underlying the pre-funded warrants was registered at the time of your
offering of the pre-
       funded warrants. Also, tell us (1) whether any leak-out agreements
entered into in
       connection with that offering or otherwise present risks that should be
disclosed in this
 Jennifer K. Simpson, Ph.D.
Delcath Systems, Inc.
December 12, 2018
Page 2
      registration statement, and (2) whether you plan to withdraw or amend the
post-effective
      amendment filed April 20, 2018.
Exhibits

3.    Please reconcile your response to prior comment 6 with your reference to
subordinated
      debt securities on page 8 and your reference to "one or more indentures"
on page 10.
      Also, if you intend to register only senior debt securities for sale as
indicated in your
      response, please revise the title of the offered securities in your fee
table, on your
      prospectus cover and elsewhere in your prospectus as appropriate; see
Instruction 1 to
      Regulation S-K Item 202.
      Please contact Caleb French at 202-551-6947 or Russell Mancuso, Legal
Branch Chief, at
202-551-3617 with any questions.



                                                            Sincerely,
FirstName LastNameJennifer K. Simpson, Ph.D.
                                                            Division of
Corporation Finance
Comapany NameDelcath Systems, Inc.
                                                            Office of
Electronics and Machinery
December 12, 2018 Page 2
cc:       Jolie Kahn, Esq.
FirstName LastName