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SEC Company Response from Pulmonx (LUNG) — Nov 24, 2025

Pulmonx Corp
Date: Nov. 24, 2025 · CIK: 0001127537 · Accession: 0001193125-25-294067

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File numbers found in text: 333-290560

Date
November 24, 2025
Author
PULMONX CORPORATION
Form
CORRESP
Company
Pulmonx Corp

Letter

RE: Pulmonx Corporation Registration Statement on Form S-3 File No. 333-290560 Ladies and Gentlemen: Pulmonx Corporation (the “ Registrant ”) hereby requests that the U.S. Securities and Exchange Commission (the “ Commission ”) take appropriate action to cause the above-referenced Registration Statement on Form S-3 to become effective on November 25, 2025, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes John T. McKenna of Cooley LLP, counsel to the Registrant, to make such request on its behalf. Once the Registration Statement has been declared effective, please orally confirm that event with John T. McKenna of Cooley LLP, counsel to the Registrant, at (650) 843-5059.

David A. Lehman General Counsel Telephone: 650.934.2604 Dlehman@Pulmonx.com Admitted to Practice: New York Registered In-House Counsel: California November 24, 2025 United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549

Very truly yours,
PULMONX CORPORATION

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CORRESP
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 filename1.htm

 CORRESP

 David A. Lehman
 General Counsel Telephone:
650.934.2604 Dlehman@Pulmonx.com
 Admitted to Practice: New York
 Registered In-House Counsel: California
 November 24, 2025 
 United States Securities and Exchange Commission Division of
Corporation Finance 100 F Street, N.E. 
 Washington, D.C. 20549

 RE:
 Pulmonx Corporation
 Registration Statement on Form S-3 
 File No. 333-290560
 Ladies and Gentlemen:
 Pulmonx Corporation (the “ Registrant ”) hereby requests that the U.S. Securities and Exchange Commission (the
“ Commission ”) take appropriate action to cause the above-referenced Registration Statement on Form S-3 to become effective on November 25, 2025, at 4:00 p.m., Eastern Time, or as soon
thereafter as is practicable or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes John T. McKenna of Cooley LLP, counsel to the Registrant, to make such
request on its behalf. Once the Registration Statement has been declared effective, please orally confirm that event with
John T. McKenna of Cooley LLP, counsel to the Registrant, at (650) 843-5059.

 Very truly yours,

 PULMONX CORPORATION

 By:

 /s/ David Lehman

 Name:

 David Lehman

 Title:

 General Counsel
 cc: John T. McKenna, Cooley LLP
 700 Chesapeake Drive /
Redwood City / California 94063 / Tel: (650) 364-0400 / Fax: (650) 364-0403 / www.pulmonx.com