United States securities and exchange commission logo April 11, 2023 Raffi Asadorian Chief Financial Officer ACELRX PHARMACEUTICALS INC 25821 Industrial Boulevard Suite 400 Hayward, CA 94545 Re: ACELRX PHARMACEUTICALS INC Form 8-K filed March 30, 2023 Dear Raffi Asadorian: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Life Sciences