April 25, 2025 John Belizaire Chief Executive Officer Soluna Holdings, Inc. 325 Washington Ave Extension Albany, NY 12205 Re: Soluna Holdings, Inc. Registration Statement on Form S-3 Filed April 18, 2025 File No. 333-286638 Dear John Belizaire: 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 David Gessert at 202-551-2326 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets