SecProbe.io

Mail Stop 6010
  November 13, 2007

Gail S. Page
President and Chief Executive Officer Vermillion, Inc. 6611 Dumbarton Circle Fremont, California 94555
Re: Vermillion, Inc.  Response Letter filed on October 30, 2007  Registration Statement on Form S-1
 File No. 333-146354
 Dear Ms. Page:
We have limited our review of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 1. We note from your responses to our prio r comments that some of your selling
stockholders are affiliates of a broker-d ealer.  If a selling stockholder is an
affiliate of a broker-dealer, it must be iden tified as an underwriter with respect to
the securities it is offering for resale unl ess that selling stockholder is able to
represent in the prospectus , in addition to having pur chased the shares in the
ordinary course of business,  that at the time of such purchase of the securities to
be resold, the seller had no agreements or understandings, direct ly or indirectly,
with any person to distribute the securities.

* * * * *

Gail S. Page
Vermillion, Inc. November 13, 2007 Page 2
As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.

We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.
 You may contact Tim Buchmiller at ( 202) 551-3635 or me at (202) 551-3444
with any other questions.   Sincerely,
 Perry Hindin
 Special Counsel

cc: Robert Claassen, Esq. (via fax)