September 29, 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 September 26, 2025 File No. 333-290546 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 Sonia Bednarowski at 202-551-3666 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets