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                             September 14, 2021

       Branislav Vajdic
       Chief Executive Officer
       HeartBeam, Inc.
       2118 Walsh Avenue, Suite 210
       Santa Clara, CA 95050

                                                        Re: HeartBeam, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 7,
2021
                                                            File No. 333-259358

       Dear Dr. Vajdic:

             We have reviewed your amended registration statement and have the
following
       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.
Unless we note
       otherwise, our references to prior comments are to comments in our July
21, 2021 letter.

       Registration Statement on Form S-1, Filed September 7, 2021

       Dilution, page 35

   1.                                                   We note your response
to comment 4 and your revised disclosure in the dilution section.
                                                        Please reconcile the
statement that, "The amount of Common Stock outstanding excludes
                                                        Common Stock issuable
on a Qualified Financing such as this IPO, at a conversion price
                                                        equal to seventy (70)%
of the price per share in the public offering" and your disclosure
                                                        that, "... and after
the conversion of the Convertible Notes (and interest) through this
                                                        Qualified Financing (as
defined in the Convertible Notes), the Company   s pro forma as
                                                        adjusted net tangible
book value as of        , 2021 would have been $        or $    per
                                                        share" or advise.
 Branislav Vajdic
FirstName
HeartBeam,LastNameBranislav  Vajdic
            Inc.
Comapany 14,
September  NameHeartBeam,
               2021        Inc.
September
Page 2     14, 2021 Page 2
FirstName LastName
Business
Overview
FDA Regulatory Path, page 48

2.       On page 48 you state:    We have finished an internal pilot study on
40 subjects and the
         results indicate that our synthesized 12-lead ECG is a better match to
the standard 12-lead
         ECG recording than the FDA cleared synthesized 12-lead ECG device that
is in the
         market.    Please revise to provide the details of this study.
       You may contact Mary Mast at 202-551-361 or Kevin Kuhar at 202-551-3662
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Margaret Schwartz at 202-551-7153 or Tom Kluck at 202-551-3233 with any
other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences
cc:      Scott Linsky, Esq.