United States securities and exchange commission logo

                           June 17, 2020

       Vincent J. Angotti
       Chief Executive Officer
       Acelrx Pharmaceuticals Inc.
       351 Galveston Drive
       Redwood City, CA 94063

                                                        Re: Acelrx
Pharmaceuticals Inc.
Statement on Form S-3
                                                            Filed June 12, 2020
                                                            File No. 333-239156

       Dear Mr. Angotti:

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

               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 Paul
Fischer at 202-551-3415 with any questions.


                           Division of Corporation Finance

                           Office of Life Sciences
       cc:                                              David Ambler, Esq.