254 West 31st Street, 11th Floor
New York, New York 10001


September 29, 2023



Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Brian Fetterolf at 202-551-6613


Re: XWELL, Inc.
  Registration Statement on Form S-3
  Filed August 4, 2023
  (Commission File No. 333-273726)


Dear Sir or Madam:


In accordance with Rule 461 under the Securities Act of 1933, as amended, XWELL, Inc. (the “Company”) hereby requests that the Registration Statement referred to above be declared effective on Friday, September 29, 2023 at 4:30 p.m. E.T. or as soon thereafter as shall be practicable.


Very truly yours,


/s/ Cara Soffer


By: Cara Soffer
  General Counsel
cc: Robert J. Endicott
  Bryan Cave Leighton Paisner LLP