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corresp

(415) 856-7049

robertpurcell@paulhastings.com

November 9, 2007

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Tim Buchmiller

Re: Registration Statement on Form S-1 (file no. 333-145354) of Vermillion, Inc.

Dear Mr. Buchmiller:

As a follow up to our telephone conversations with the staff of the Division of Corporation Finance
(the “Staff”) on November 7, 2007 and November 8, 2007, we are filing this letter on behalf of
Vermillion, Inc. (the “Company”) to provide the Staff with certain supplemental information
relating to the warrants exercisable for shares of the Company’s
common stock some of which are proposed to
be registered in the above referenced registration statement (the “Registration Statement”). The
information below updates and supersedes the related information which was set forth in the
Company’s responses to the Staff’s comments dated October 15, 2007 which were filed via EDGAR on
October 30, 2007.

The Company supplementally advises the Staff that the form of the warrants which were issued in the
Company’s private placement which closed on August 29, 2007 (the “Private Placement”), which is
attached as Exhibit C to the Securities Purchase Agreement relating to the Private Placement which
was filed as Exhibit 10.57 to the Registration Statement, contains a provision limiting a warrant
holder’s exercise of its warrant if such holder would beneficially own more than 4.99% of the
Company’s outstanding common stock following such exercise. This limitation provision is bracketed
in the form of warrant with a notation that such provision is to be included in the warrant at the
request of the purchaser. All of the warrants issued in the Private Placement contain such
limitation except for those held by Oppenheimer & Co. Inc., Quest Diagnostics Incorporated and
Phronesis Partners L.P.

The Company plans to file as a separate exhibit to its Quarterly Report on Form 10-Q for the
quarter ended September 30, 2007 the form of warrant with a
schedule listing all of the warrants issued and indicating which warrants do not contain such beneficial ownership
limitation provision. The Company will incorporate this exhibit by reference into Amendment No. 1
to the Registration Statement when filed.

November 9, 2007

Page 2

If you have any further questions or concerns please feel free to contact me at (415) 856-7049.

    Sincerely,

    /s/ Robert Purcell

    Robert Purcell

    for PAUL, HASTINGS, JANOFSKY & WALKER LLP

cc: Gail S. Page, Chief Executive Officer, Vermillion, Inc.