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SEC Comment Letter for Pulmonx (LUNG) — Nov 18, 2025

Pulmonx Corp
Date: Nov. 18, 2025 · CIK: 0001127537 · Accession: 0000000000-25-010820

Regulatory Compliance Offering / Registration Process

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File numbers found in text: 333-290560

Date
November 18, 2025
Author
Steven Williamson
Form
UPLOAD
Company
Pulmonx Corp

Letter

November 18, 2025 Steven Williamson President and Chief Executive Officer Pulmonx Corp 700 Chesapeake Drive Redwood City, CA 94063 Re:Pulmonx Corp Registration Statement on Form S-3 Filed September 26, 2026 File No. 333-290560 Dear Steven Williamson: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Robert Augustin at 202-551-8483 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc:John McKenna

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November 18, 2025
Steven Williamson
President and Chief Executive Officer
Pulmonx Corp
700 Chesapeake Drive
Redwood City, CA 94063
Re:Pulmonx Corp
Registration Statement on Form S-3
Filed September 26, 2026
File No. 333-290560
Dear Steven Williamson:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Robert Augustin at 202-551-8483 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:John McKenna