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                              September 27, 2023

       Amy Trombly
       Chief Executive Officer
       Sonoma Pharmaceuticals, Inc.
       5445 Conestoga Court, Suite 150
       Boulder, CO 80301

                                                        Re: Sonoma 
Pharmaceuticals, Inc.
                                                            Registration 
Statement on Form S-1
                                                            Filed September 19, 
2023
                                                            File No. 333-274582

       Dear Amy Trombly:

              We have limited our review of your registration statement to 
those issues we have
       addressed in our comments. In some of our comments, we may ask you to 
provide us with
       information so we may better understand your disclosure.

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

       Registration Statement on Form S-1 filed September 19, 2023

       Cover Page

   1.                                                   Please revise your 
cover page to disclose the date the offering will end. Refer to
                                                        Item 501(b)(8)(iii) of 
Regulation S-K for guidance.
               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.

              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.
 Amy Trombly
Sonoma Pharmaceuticals, Inc.
September 27, 2023
Page 2

       Please contact Cindy Polynice at 202-551-8707 or Jason Drory at 
202-551-8342 with any
other questions.



                                                         Sincerely,
FirstName LastNameAmy Trombly
                                                         Division of 
Corporation Finance
Comapany NameSonoma Pharmaceuticals, Inc.
                                                         Office of Life 
Sciences
September 27, 2023 Page 2
cc:       Andrew J. Merken, Esq.
FirstName LastName