United States securities and exchange commission logo

                            May 17, 2023

       Dennis Dean
       Chief Financial Officer
       AirSculpt Technologies, Inc.
       1111 Lincoln Road, Suite 802
       Miami Beach, FL 33139

                                                        Re: AirSculpt
Technologies, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2022
                                                            Response dated May
8, 2023
                                                            File No. 001-40973

       Dear Dennis Dean:

              We have reviewed your May 8, 2023 response to our comment letter
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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       April 13, 2023 letter.

       Form 10-K for the fiscal year ended December 31, 2022

       Item 7. Managements Discussion and Analysis of Financial Condition and
Results of Operations
       Non-GAAP Financial Measures, page 49

   1.                                                   We have reviewed your
response to prior comment one and it appears that pre-opening de
                                                        novo costs represent
costs incurred as part of the company   s growth strategy and such
                                                        costs are normal,
recurring expenses. Consistent with the guidance in Question 100.01 of
                                                        the CD&I related to
Non-GAAP Financial Measures, updated December 13, 2022, please
                                                        revise future filings
to remove the adjustment for pre-opening de novo costs from your
                                                        non-GAAP measures.
   2.                                                   We note you use
tax-adjusted amounts to reconcile Adjusted Net Income to Net loss.
                                                        Please tell us how your
presentation is consistent with Question 102.11 of the CD&I
 Dennis Dean
AirSculpt Technologies, Inc.
May 17, 2023
Page 2
         related to Non-GAAP Financial Measures, or revise your presentation to
conform to the
      You may contact Christie Wong at 202-551-3684 or Michael Fay, Senior
Accountant, at 202-551-3812 with any questions.

FirstName LastNameDennis Dean
                                                            Division of
Corporation Finance
Comapany NameAirSculpt Technologies, Inc.
                                                            Office of
Industrial Applications and
May 17, 2023 Page 2                                         Services
FirstName LastName