Surface Oncology, Inc.

50 Hampshire Street, 8th Floor

Cambridge, Massachusetts 02139

May 6, 2019

Via EDGAR Transmission

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Surface Oncology, Inc.: Registration Statement on Form S-3 filed May 1, 2019 (File No. 333-231144)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Surface Oncology, Inc. (the “Company”) hereby requests that the effective date of the above-referenced registration statement (the “Registration Statement”) be accelerated to May 8, 2019, at 4:01 pm Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel, Goodwin Procter LLP, request by telephone that such Registration Statement be declared effective at some other time. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

If you have any questions regarding this request, please contact Seo Salimi of Goodwin Procter LLP at (212) 459-7234.

Sincerely,

Surface Oncology, Inc.

/s/ J. Jeffrey Goater

J. Jeffrey Goater

President and Chief Executive Officer

cc: Jessica Fees, Surface Oncology, Inc.

Kingsley L. Taft, Esq., Goodwin Procter LLP

Seo Salimi, Esq., Goodwin Procter LLP