SecProbe.io

December  11, 2012

Via E -mail
Douglas A. Michels
President and Chief Executive Officer
OraSure Technologies, Inc.
220 East First Street
Bethlehem, PA  18015

Re: OraSure  Technologies, Inc.
Amendment No. 1 to Registration Statement on Form S-3
Filed November  30, 2012
  File No.  333-184190

Dear Mr. Michels :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   Where you do not believe our c omments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments,  we may have additional comments.

Prospectus Summary

1. Please tell us why you believe your disclosure added in response to prior comment 1
adequately highlights the magnitude of developments that will cause the anticipated
increase in net loss and the p otential decrease in revenues mentioned in your November
7, 2012 conference call.  Also, please provide us your analysis of why you believe
including this information near the end of a 10 -page summary adequately highlights the
issues; refer to Updated S taff Legal Bulletin No. 7 (June 7, 1999) sample comments 28
and 29.

Exhibit 5.1

2. Refer to your response to our prior comment 3.  Please tell us what law governs the
rights. In this regard, we note that this exhibit does not address Delaware contract law.

Douglas A. Michels
OraSure Technologies, Inc.
December 11, 2012
Page 2

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 1933 and
all applicable Securities 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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commissi on from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and acc uracy of the disclosure in the filing; and

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

Please refer to Rules 460 and 461 regarding requests for acceleration.  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time for us to revie w any amendment prior to the requested effective date of the
registration statement.

Please contact Joseph McCann at (202)  551-6262 or me at (202) 551 -3617  with any
questions.

     Sincerely,

     /s/ Russell Mancuso

Russell Mancuso
 Branch Chief

cc (via email):  Ella DeTrizio , Esq. – Dechert  LLP