August 22, 2024

Steven M. Foster
Chief Executive Officer and President
Tenon Medical, Inc.
104 Cooper Court
Los Gatos, CA 95032

       Re: Tenon Medical, Inc.
           Registration Statement on Form S-1
           Filed August 14, 2024
           File No. 333-281531
Dear Steven M. Foster:

     We have conducted a limited review of your registration statement and have
the following
comment(s).

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

Registration Statement on Form S-1 filed August 14, 2024
Use of Proceeds, page 46

1.     As this is a best-efforts offering with no minimum investment required,
please revise your
       Use of Proceeds section to include a sensitivity analysis reflecting
varying amounts of
       possible sales (e.g., 25%, 50%, 75%), to supplement the current 100%
presentation.
Dilution, page 48

2.     As this is a best-efforts offering with no minimum investment required,
please also revise
       your Dilution section to include a sensitivity analysis reflecting
varying amounts of
       possible sales (e.g., 25%, 50%, 75%, 100%) rather than a single
presentation.
        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.
 August 22, 2024
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.

       Please contact Conlon Danberg at 202-551-4466 or Margaret Sawicki at
202-551-7153
with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Jeffrey P. Wofford, Esq.