PILLSBURY WINTHROP SHAW PITTMAN LLP
P.O. Box 7880
San Francisco, CA 94120
Tel: (415) 983-1000
Fax: (415) 983-1200

July 15, 2005

VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

     Re: Genomic Health, Inc.
Registration Statement on Form S-1

Ladies and Gentlemen:

     On behalf of Genomic Health, Inc. (the “Registrant”), transmitted herewith for filing with the Securities and Exchange Commission under the Securities Act of 1933, as amended (the “Act”), is one conformed copy of the Registrant’s Registration Statement on Form S-1, together with the exhibits thereto (except for exhibits that will be filed by amendment). Manually executed signature pages and consents have been executed prior to the time of this electronic filing and will be retained by Registrant for five (5) years.

     The filing fee of $8,827.50 has been calculated pursuant to Rule 457(o) of the General Rules and Regulations under the Act and has been sent by wire transfer to the Commission’s lockbox at The Mellon Bank in Pittsburgh, Pennsylvania as required by Rule 13(c) of Regulation S-T. The wire was sent on Friday, June 24, 2005.

     The representatives of the underwriters have advised us that the proposed offering will be reviewed by representatives of the National Association of Securities Dealers, Inc. (the “NASD”) and that copies of the Registration Statement and Underwriting Agreement are being forwarded to the NASD.

     The Registrant and the managing underwriters have authorized us to advise you that, as contemplated by Rule 461(a) under the Act, they may make oral requests for the acceleration of the Registration Statement’s effectiveness and that they are aware of their respective obligations under the Act.

Securities and Exchange Commission
July 15, 2005
Page 2

     Please direct any questions or information regarding this filing to the undersigned at (415) 983-6117.

Very truly yours,

/s/ Justin D. Hovey

Justin D. Hovey

cc:	The Nasdaq National Market
	Randal W. Scott, Ph.D. G. Bradley Cole
	Stanton D. Wong, Esq. Gabriella A. Lombardi, Esq.