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                              June 8, 2021

       Olivier Taelman
       Chief Executive Officer
       Nyxoah SA
       Rue Edouard Belin 12
       1435 Mont-Saint-Guibert, Belgium

                                                        Re: Nyxoah SA
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted May 24,
2021
                                                            CIK No. 0001857190

       Dear Dr. Taelman:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1, Submitted
May 24, 2021

       Business
       Our Competitive Strengths, page 92

   1.                                                   We note your response
to our prior comment number 4 and your reference to continuing
                                                        to prosecute patent
applications. Please revise to clarify whether you will own any patents
                                                        arising from this
partnership or will you simply license Vanderbilt   s patents. Additionally,
                                                        on page 93 please
revise to disclose any upfront material payments and the termination
                                                        provisions of the
agreement.
 Olivier Taelman
FirstName
Nyxoah SALastNameOlivier Taelman
Comapany
June 8, 2021NameNyxoah SA
June 8,
Page 2 2021 Page 2
FirstName LastName
Clinical Results and Studies , page 106

2.       We note your response to our prior comment number 10. We understand
the language on
         page 109 and the related charts are intended to allow investors to be
able to understand the
         market in which the Company operates and to show the clinical data
generated by the
         principal hypoglossal nerve stimulation therapies. However, these
charts are the same
         charts used in the prior filing showing the results of third party
studies of that were not
         head-to-head trials and the corresponding Company   s chart appears on
the page before.
         Therefore, the graphics showing the results for your competitors on
page 109 are
         understood to be a comparison. You may note the types of metrics used
in these studies
         and the features of these other devices, such as number of incisions
required, but please
         remove the results of the competitor   s trials.
Intellectual Property, page 114

3.       We note your response to our prior comment number 12. You state that
the Clarification
         confirms that the license granted by Man & Science SA will continue in
effect until the
         last to expire patent. Please revise to state when these patents are
expected to expire. With
         respect to the Man & Science SA and Cochlear Limited agreements,
please also state
         whether you have any ongoing or future financial obligations under
either such agreement.
         To the extent you take the position that the agreement with Vanderbilt
University is not
         material, please remove all references to such agreement in the
Summary. If you wish to
         retain such description then you must file such agreement.
Certain Relationships and Related Party Transactions , page 149

4.       We note your response to our prior comment number 15. With respect to
the description
         of the Man & Science Agreement on page 149 and elsewhere, please
revise to explain the
         scope of the sleep disordered breathing field.
2. Significant accounting policies
Significant Events and Transactions of the Interim Period, page F-50

5.       We see from your disclosures that you entered into a collaboration
agreement with
         Vanderbilt University pursuant to which you are exploring additional
neurostimulation
         technologies and under this agreement, you are responsible for product
development,
         while Vanderbilt University is responsible for patent prosecution.
Please revise to disclose
         the significant terms of this in-licensing agreement, including the
term of the agreement,
         any significant milestones, and any royalties due under the agreement.
 Olivier Taelman
FirstName
Nyxoah SALastNameOlivier Taelman
Comapany
June 8, 2021NameNyxoah SA
June 8,
Page 3 2021 Page 3
FirstName LastName
       You may contact Julie Sherman at 202-551-3640 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:      John Rudy, Esq.