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                        June 25, 2024

       Justin M. Hall
       Chief Executive Officer and General Counsel
       NovaBay Pharmaceuticals, Inc.
       2000 Powell Street, Suite 1150
       Emeryville, CA 94608

                                                        Re: NovaBay 
Pharmaceuticals, Inc.
                                                            Registration 
Statement on Form S-1
                                                            Filed June 20, 2024
                                                            File No. 333-280363

       Dear Justin M. Hall:

              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 Jimmy 
McNamara at 202-551-7349 with any questions.



                                                                                
                        Sincerely,

                                                                                
                        Division of Corporation Finance
                                                                                
                        Office of Life Sciences