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CORRESP Filing

ACCURAY INC
Date: Feb. 24, 2026 · CIK: 0001138723 · Accession: 0000950103-26-002518

Offering / Registration Process

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File numbers found in text: 333-293517

Date
February 24, 2026
Author
Accuray Incorporated
Form
CORRESP
Company
ACCURAY INC

Letter

VIA EDGAR TRANSMISSION Division of Corporation Finance Attention: Ms. Jane Park Registration Statement on Form S-3 Registration No. 333-293517

Re: Accuray Incorporated

Dear Ms. Park:

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. 333-293517) (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 February 27, 2026 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
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filename1.htm

February 24, 2026

    VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Ms. Jane Park

    Re:
    Accuray Incorporated

Registration Statement on Form S-3

Registration No. 333-293517

Dear Ms. Park:

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. 333-293517) (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 February 27, 2026 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/ David Shin

    Name:
    David Shin

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

[Signature Page to Acceleration Request]