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SEC Company Response from VirnetX Holding (VHC) — May 27, 2026

VirnetX Holding Corp
Date: May 27, 2026 · CIK: 0001082324 · Accession: 0001140361-26-023009

Offering / Registration Process

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File numbers found in text: 333-295960

Date
May 27, 2026
Author
/s/ Kendall Larsen
Form
CORRESP
Company
VirnetX Holding Corp

Letter

Re:

VirnetX Holding Corporation 308 Dorla Court, Suite 206 Zephyr Cove, Nevada 89448

May 27, 2026

VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Pearlyne Paulemon

VirnetX Holding Corporation

Registration Statement on Form S-3

File No. 333-295960

Acceleration Request

Requested Date:

June 2, 2026

Requested Time:

4:00 p.m.

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, VirnetX Holding Corporation (the “ Company ”) hereby requests that the above-referenced Registration Statement on Form S-3 (File No. 333-295960) (the “ Registration Statement ”) be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon thereafter as practicable, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with the Company’s counsel, Wilson Sonsini Goodrich & Rosati, P.C., by calling Lauren Lichtblau at (650) 849-3069.

[ Signature page follows ]

Sincerely,
VirnetX Holding Corporation

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CORRESP
 1
 filename1.htm

 VirnetX Holding Corporation
 308 Dorla Court, Suite 206
 Zephyr Cove, Nevada 89448

 May 27, 2026

 VIA EDGAR
 U.S. Securities and Exchange Commission
 Division of Corporation Finance
 100 F Street, N.E.
 Washington, D.C. 20549
 Attention: Pearlyne Paulemon

 Re:

 VirnetX Holding Corporation

 Registration Statement on Form S-3

 File No. 333-295960

 Acceleration Request

 Requested Date:

 June 2, 2026

 Requested Time:

 4:00 p.m.

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, VirnetX Holding Corporation (the “ Company ”) hereby requests that the above-referenced
 Registration Statement on Form S-3 (File No. 333-295960) (the “ Registration Statement ”) be declared effective at the “Requested Date” and “Requested Time” set forth above, or as soon thereafter as practicable,
 or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective,
 please orally confirm that event with the Company’s counsel, Wilson Sonsini Goodrich & Rosati, P.C., by calling Lauren Lichtblau at (650) 849-3069.

 [ Signature page follows ]

 Sincerely,

 VirnetX Holding Corporation

 /s/ Kendall Larsen

 Kendall Larsen

 Director, Chief Executive Officer and President

 cc:

 Katherine Allanson, VirnetX Holding Corporation

 Katharine Martin, Wilson Sonsini Goodrich & Rosati, P.C.

 Lauren Lichtblau, Wilson Sonsini Goodrich & Rosati, P.C.