SecProbe.io

Mail Stop 3030
April 29, 2016

Via E -Mail
Joseph M. Hogan
President and Chief Executive Officer
Align Technology, Inc.
2560 Orchard Parkway
San Jose, CA 95131

Re: Align Technology, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2015
Filed February 25, 2016
File No. 000 -32259

Dear Mr. Hogan :

We have reviewed your filing an d have the following comment.  In our comment , we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment applies  to your facts and circumst ances , please tell us why in your response.

After reviewing your response to this comment, we may have  additional comments.

Intellectual Property, page 10

1. We note your disclosure that the expiration of some of your key patents beginning i n
2017 may result in additional competition.  Please ensure that you future filings, as
appropriate, disclose the effects of those patents on your business and clarify how the
expiration of those patents may result in additional competition.  For example, do you
expect more competitors to enter the market?  Do you expect existing competitors to
begin offering products more similar to yours?

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain t hat the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the  accuracy
and adequacy of the disclosures they have made.

Joseph M. Hogan
Align Technology, Inc.
April 29, 2016
Page 2

  In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Brian Soares  at (202) 551 -3580 or Tim Buchmiller, Senior Attorney,  at
(202) 551 -3635 with any questions.

Sincerely,

/s/ Tim Buchmiller for

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: Chris Fennell , Esq.
Wilson Sonsini Goodrich & Rosati