January 21, 2025 Dr. Raluca Dinu Chief Executive Officer QT Imaging Holdings, Inc. 3 Hamilton Landing, Suite 160 Novato, CA 94949 Re: QT Imaging Holdings, Inc. Registration Statement on Form S-1 Filed January 16, 2025 File No. 333-284317 Dear Dr. Raluca Dinu: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Jane Park at 202-551-7439 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Jeffrey Selman, Esq.