July 16, 2019

William Plovanic
President and Chief Financial Officer
Obalon Therapeutics, Inc.
5421 Avenida Encinas, Suite F
Carlsbad, California 92008

       Re: Obalon Therapeutics, Inc.
           Registration Statement on Form S-1
           Filed June 21, 2019
           File No. 333-232276

Dear Mr. Plovanic:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-1 filed June 21, 2019

Our restated certificate of incorporation designates the Court of Chancery of
the State of
Delaware, page 70

1.     We note that your forum selection provision identifies the Court of
Chancery of the State
       of Delaware as the exclusive forum for certain litigation, including any
"derivative
       action." Please disclose whether this provision applies to actions
arising under the
       Securities Act or Exchange Act. In that regard, we note that Section 27
of the Exchange
       Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
       liability created by the Exchange Act or the rules and regulations
thereunder, and Section
       22 of the Securities Act creates concurrent jurisdiction for federal and
state courts over
       all suits brought to enforce any duty or liability created by the
Securities Act or the rules
       and regulations thereunder. If the provision applies to Securities Act
claims, please also
 William Plovanic
Obalon Therapeutics, Inc.
July 16, 2019
Page 2
      revise your prospectus to state that there is uncertainty as to whether a
court would
      enforce such provision and that investors cannot waive compliance with
the federal
      securities laws and the rules and regulations thereunder.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Thomas Jones at 202-551-3602 or Russell Mancuso, Branch
Chief, at 202-
551-3617 with any questions.



                                                            Sincerely,
FirstName LastNameWilliam Plovanic
                                                            Division of
Corporation Finance
Comapany NameObalon Therapeutics, Inc.
                                                            Office of
Electronics and Machinery
July 16, 2019 Page 2
cc:       B. Shayne Kennedy
FirstName LastName