TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 17, 2024 Scott Hutton Chief Executive Officer Biodesix, Inc. 919 West Dillon Rd. Louisville, Colorado 80027 Re: Biodesix, Inc. Registration Statement on Form S-1 Filed April 23, 2024 File No. 333-278881 Dear Scott Hutton: We have conducted a limited review of your registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Form S-1 filed April 23, 2024 General 1. We note your disclosure on page 153 that your selling securityholders may sell their securities through one or more underwritten offerings on a firm commitment or best efforts basis. Please confirm your understanding that the retention by a selling stockholder of an underwriter would constitute a material change to your plan of distribution requiring a post-effective amendment. Refer to your undertaking provided pursuant to Item 512(a)(1)(iii) of Regulation S-K. 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 Scott Hutton Biodesix, Inc. May 17, 2024 Page 2 statement. Please contact Jane Park at 202-551-7439 or Lauren Nguyen at 202-551-3642 with any other questions. Sincerely, FirstName LastNameScott Hutton Division of Corporation Finance Office of Industrial Applications and Comapany NameBiodesix, Inc. Services May 17, 2024 Page 2 cc: Samir Gandhi, Esq. FirstName LastName