SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
       March 19 , 2015

Via E -mail
Gregory E. Lichtwardt
Executive Vice President and Chief Financial Officer
Accuray Incorporated
1310 Chesapeake Terrace
Sunnyvale, California  94089

 Re: Accuray Incorporated
Form 10 -K for the Fiscal Year E nded June 30, 2014
Filed August 29, 2014
Form 10 -Q for the Fiscal Quarter  Ended December  31, 2014
  Filed February 6, 2015
File No. 001-33301

Dear Mr.  Lichtwardt ,

We have reviewed your response letter dated February 27, 2015 and related
filing s and have the following comment s.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  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 co mments apply to your facts and circumstances, please tell us why in
your response.

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

Form 10 -K for the Fiscal Year Ended June 30, 2014

Consolidated Financial Statements

Note 2.  Summary of Significant Accounting Policies, Segment Information, page 92

1. We note in your response to prior comment 1 that you believe the CyberKnife and
the TomoTherapy systems are similar products that do not require separate
product line disc losure under FASB ASC 280 -10-50-40.  We note that the
company has a narrow product line, comprised of the Cyberknife and
TomoTherapy systems.   We also note that the two systems are separately
discussed in detail in your 10 -K and on your website, noting th e differences in the

Gregory E. Lichtwardt
Accuray Incorporated
March 1 9, 2015
Page 2

 capabilities of the two products.  To help us better understand your determination
please further explain to us the similarities and the differences between the two
systems and their uses.  Also, explain to us how the narrowness of you r product
line was considered in assessing whether disaggregated disclosure is required
under FASB ASC 280 -10-50-40.

Form 10 -Q for the Fiscal Quarter Ended December 31, 2014
Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 16
2. Please expand the analysis that you provided to us in response to prior comment 6
to:
 address Regulation S -K Item 303(a)(3)(iii), including why you believe your
disclosure provides all required information regarding the extent  of changes
attributable to volume versus price, and the reasons for those changes.   In this
regard, we note that page 19 of your most recent Form 10 -Q attributes
changes in the dollar value of orders to “product mix” and page 20 attributes
changes in product net revenue to “product configuration mix” and changes in
gross profit to “prod uct mix;” include in your response to this comment your
analysis of (1) how your disclosure permits investors to understand how and
why mix changed in a manner that resulted in these effects, (2) whether and
why there are material decreases in the price of  a class of your products that
would not be evident from disclosure that addresses solely aggregate price
changes.
 address why you believe your disclosure in your most recent Form 10 -K
provides all disclosure required by Regulation S -K Item 101(c)(1)(i),  or
provide us the disclosure that you intend to include in future filings to do so.

3. We note the last paragraph of your response to prior comment 6.   When you
present multiple factors affecting margins, please ensure that your future filings
clearly disc uss the magnitude of the effect of each material factor.

Backlog, page 18

4. We note the statement in your response to prior comment 4 that you believe your
disclosure addresses the portion of your backlog not reasonably expected to be
filled within the c urrent fiscal year.   Expand your response to clarify where you
believe your disclosure provides this information.

Net Revenue, page 20

5. Please reconcile the product revenue disclosed in your periodic reports with the
individual product volume and price information that you provided in response to
prior comment 6.

Gregory E. Lichtwardt
Accuray Incorporated
March 1 9, 2015
Page 3

 You may Kristin Lochhead at (202) 551 -3664 or Gary Todd, Senior Accountant,
at (202) 551 -3605 if you h ave questions regarding comments  on the financial statemen ts
and related matters.  Please contact Kate Maher at (202) 551 -3184 or Russell Mancuso,
Legal Branch Chief, at (202) 551 -3617 with any other questions .

Sincerely,

            /s/ Gary Todd for

                 Brian Cascio
 Accounting Branch Chief