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CORRESP Filing

ACCURAY INC
Date: Aug. 29, 2025 · CIK: 0001138723 · Accession: 0000950103-25-010949

Offering / Registration Process

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File numbers found in text: 333-288998

Date
September 2, 2025
Author
Accuray Incorporated
Form
CORRESP
Company
ACCURAY INC

Letter

VIA EDGAR TRANSMISSION U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Mr. Conlon Danberg

Re: Accuray Incorporated Registration Statement on Form S-3 Registration No. 333-288998

Dear Mr. Danberg:

In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 (File No. 333-288998) (the " Registration Statement ") of Accuray Incorporated. We respectfully request that the Registration Statement be declared effective as of 9:00 A.M. Eastern Time on September 2, 2025 or as soon as practicable thereafter, or at such other time as our legal counsel, Davis Polk & Wardwell LLP, may request by a telephone call to the staff of the U.S. Securities and Exchange Commission.

Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling Alan F. Denenberg at (650) 752-2004.

[ Signature page follows ]

Very truly yours,
Accuray Incorporated

Show Raw Text
CORRESP
 1
 filename1.htm

 August 29,
2025

 VIA EDGAR TRANSMISSION

 U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

Attention: Mr. Conlon Danberg

 Re:
 Accuray Incorporated
Registration Statement on Form S-3
Registration No. 333-288998

 Dear Mr. Danberg:

 In accordance with Rule 461 under the Securities Act of 1933, as
amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 (File No. 333-288998) (the
" Registration Statement ") of Accuray Incorporated. We respectfully request that the Registration Statement be
declared effective as of 9:00 A.M. Eastern Time on September 2, 2025 or as soon as practicable thereafter, or at such
other time as our legal counsel, Davis Polk & Wardwell LLP, may request by a telephone call to the staff of the U.S. Securities
and Exchange Commission.

 Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling Alan F. Denenberg at (650) 752-2004.

 [ Signature page follows ]

 Very truly yours,

 Accuray Incorporated

 By:
 /s/
 Jesse Chew

 Name:
 Jesse Chew

 Title:
 Senior Vice President, Chief Legal Officer and
 Corporate Secretary

 [ Signature Page to Acceleration Request ]