United States securities and exchange commission logo November 21, 2022 Vincent J. Angotti Chief Executive Officer AcelRx Pharmaceuticals Inc. 25821 Industrial Boulevard, Suite 400 Hayward, CA 94545 Re: AcelRx Pharmaceuticals Inc. Registration Statement on Form S-3 Filed November 15, 2022 File No. 333-268396 Dear Vincent J. Angotti: 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 Christine Westbrook at 202-551-5019 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences