November 14, 2019 Raymond W. Cohen Chief Executive Officer Axonics Modulation Technologies, Inc. 26 Technology Drive Irvine, California 92618 Re: Axonics Modulation Technologies, Inc. Registration Statement on Form S-3 Filed November 6, 2019 File No. 333-234546 Dear Mr. Cohen: 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 Chris Edwards at (202) 551-6761 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Jason C. Dreibelbis