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                             January 28, 2021

       Anish Bhatnagar, M.D.
       Chief Executive Officer
       Soleno Therapeutics, Inc.
       203 Redwood Shores Parkway, Suite 500
       Redwood City, CA 94065

                                                        Re: Soleno
Therapeutics, Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed January 14,
2021
                                                            File No. 333-252108

       Dear Dr. Bhatnagar:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies 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 this comment, we may have additional comments.

       Registration Statement on Form S-3 filed January 14, 2021

       Cover Page

   1.                                                   It appears that you are
relying on General Instruction I.B.6 of Form S-3. If true, please
                                                        revise your prospectus
cover page to disclose the calculation of the aggregate market
                                                        value of your
outstanding voting and nonvoting common equity and the amount of all
                                                        securities offered
pursuant to General Instruction I.B.6 during the prior 12 calendar month
                                                        period that ends on,
and includes, the date of the prospectus. Refer to Instruction 7 to
                                                        General Instruction
I.B.6. Otherwise, please provide us your analysis demonstrating your
                                                        eligibility to use Form
S-3.
               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.
 Anish Bhatnagar, M.D.
Soleno Therapeutics, Inc.
January 28, 2021
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jeffrey Gabor at 202-551-2544 or Laura Crotty at
202-551-7614 with
any questions.



                                                           Sincerely,
FirstName LastNameAnish Bhatnagar, M.D.
                                                           Division of
Corporation Finance
Comapany NameSoleno Therapeutics, Inc.
                                                           Office of Life
Sciences
January 28, 2021 Page 2
cc:       Jesse Schumaker, Esq.
FirstName LastName