April 7, 2026

John Belizaire
Chief Executive Officer
Soluna Holdings, Inc
325 Washington Avenue Extension
Albany, New York 12205

        Re: Soluna Holdings, Inc
            Draft Registration Statement on Form S-1
            Submitted April 1, 2026
            CIK No. 0000064463
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 Lulu Cheng at 202-551-3811 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Crypto
Assets
cc:    Steven Siesser