March 18, 2019

Erica J. Rogers
Chief Executive Officer
Silk Road Medical Inc
1213 Innsbruck Dr.
Sunnyvale, CA 94089

       Re: Silk Road Medical Inc
           Registration Statement on Form S-1
           Filed March 4, 2019
           File No. 333-230045

Dear Ms. Rogers:

       We have reviewed your registration statement and have the following
comments. In
some of our comments, we may ask you to provide us with information so we may
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
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1 filed March 4, 2019

Common Stock Valuation and Stock-Based Compensation, page 81

1.     We see on page F-29 that the weighted average exercise price of options
issued during
       2018 is significantly less than the $4.50 exercise price of certain
options issued during
       2017. Describe to us the material positive and negative events occurring
during the period
       which contributed to the variances in the estimated fair value of your
common shares
       underlying these option issuances. Please also provide us with the
underlying common
       stock share price of the equity instruments issued and progressively
bridge to the current
       estimated IPO price the fair value per share determinations used for
each option grant
       since January 1, 2018. We will delay our assessment of your response
pending inclusion
       of the estimated IPO price in the filing.
 Erica J. Rogers
Silk Road Medical Inc
March 18, 2019
Page 2
Description of Capital Stock
Exclusive Forum, page 160

2.     We note your response to comment six of our prior letter. Please
disclose whether this
       provision applies to claims under the Exchange Act. Also revise to state
that stockholders
       will not be deemed to have waived the company's compliance with the
federal securities
       laws and the rules and regulations thereunder. Please make conforming
changes to the
       risk factor on page 55.
Note 4. Fair Value Measurements, page F-19

3.     Please revise to disclose the fair value of your common shares at each
period end as it is a
       significant unobservable input underlying the level 3 fair value
measurements. Refer to
       ASC 820-10-50-2bbb.
        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

        You may contact Gary Newberry, Staff Accountant, at (202) 551-3761 or
Kevin Kuhar,
Accounting Branch Chief, at (202) 551-3662 if you have questions regarding
comments on the
financial statements and related matters. Please contact Sergio Chinos, Staff
Attorney, at (202)
551-7844 or Kate McHale, Staff Attorney, at (202) 551-3464 with any other

FirstName LastNameErica J. Rogers
                                                             Division of
Corporation Finance
Comapany NameSilk Road Medical Inc
                                                             Office of
Electronics and Machinery
March 18, 2019 Page 2
cc:       Philip H. Oettinger
FirstName LastName