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                            October 7, 2021

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

                                                        Re: HeartBeam, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed October 4,
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.

       Amendment No. 1 to Registration Statement on Form S-1 filed October 4,
2021

       Business
       Preparations for FDA Clearance Submissions and Design for Manufacturing,
page 59

   1.                                                   We note your disclosure
that you have a contract with Ximedica to prepare your ER
                                                        Product for FDA 510(k)
clearance submission. Please discuss the principal terms of this
                                                        agreement and file the
agreement as an exhibit. See Items 101(h)(4) and 601(b)(10) of
                                                        Regulation S-K.
       Executive Compensation
       Summary Compensation Table, page 66

   2.                                                   In the summary
compensation table, please include all compensation and related
                                                        information. See Item
402(n) of Regulation S-K. For example, please include the unvested
 Branislav Vajdic
HeartBeam, Inc.
October 7, 2021
Page 2
      service warrants as disclosed in the beneficial ownership table on page
74 or advise.
Director Compensation, page 67

3.    Please revise the table to include the information required by Item
402(r) of Regulation S-
      K. For example, please reconcile the compensation in the table with the
amounts disclosed
      in the beneficial ownership table on page 74, including compensation to
Willem Pieter
      Elfrink and other stock options granted to directors or advise.
Outstanding Equity Awards at Fiscal Year-End 2020, page 67

4.    Please reconcile the information in the table, including the option
exercise price, with your
      disclosure regarding stock options on pages 74 and F-14 or advise. See
Item 402(p) of
      Regulation S-K.
Certain Relationships and Related Transactions, page 75

5.    Please describe each transaction and disclose the name of the related
party, the basis on
      which the person is a related party and the approximate dollar value. See
Item 404 of
      Regulation S-K. For example, please provide this disclosure for purchases
by related
      parties in the 2015 Notes and other investments. In addition, please
include the milestone
      warrants as described in Part II of the registration statement or advise.
       You may contact Mary Mast at 202-551-3613 or Kevin Kuhar at 202-551-3662
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tom Kluck at 202-551-3233 or Celeste Murphy at 202-551-3257 with any
other
questions.



                                                            Sincerely,
FirstName LastNameBranislav Vajdic
                                                            Division of
Corporation Finance
Comapany NameHeartBeam, Inc.
                                                            Office of Life
Sciences
October 7, 2021 Page 2
cc:       Scott Linsky, Esq.
FirstName LastName