SecProbe.io

Mail Stop 3030

June 26 , 2018

Via E -mail
R. Erik Holmlin, Ph.D.
President and Chief Executive Officer
Bionano Genomics, Inc.
9640 Towne Centre Drive, Suite 100
San Diego, California 92121

Re: Bionano Genomics, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S -1
Submitted June 12, 2018
  CIK No. 0001411690

Dear Dr. Holmlin :

We have reviewed your amended draft registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with i nformation so we
may better understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Overview,  page 1

1. It appears from your response to comment 3 that your beliefs  regarding cost -effectiveness
of your products are based on your expectations rather than existing facts.  If so, please
revise to disclose the basis of your beliefs.  Also, tell us wheth er “small variations” and
“large variations” are industry terms of art.  In this regard, it is unclear whether
sequencing systems could detect “large variations,” given the number of base pairs you
indicate in your response.

2. We note your response to comm ent 4.  Please revise to disclose the significance to your
business of each of the customers named in your disclosure.

R. Erik Holmlin, Ph.D.
Bionano Genomics, Inc.
June 26, 2018
Page 2

3. Please expand your revisions in response to comment 5 to clarify how the market data in
your submission reflects the research use only designation of your product.  Also, we
note the revisions regarding laboratory developed tests.  Please tell us how regulatory
approval of laboratory developed tests would impact your addressable market, and revise
your disclosure to briefly describe any r egulatory uncertainty regarding laboratory
developed tests.

Market Opportunity, page 2

4. We note your response to comment 6.  Please tell us whether any of the installed base of
high throughput sequencers are marketed as other than research use only.

Use of Proceeds, page 46

5. We note your response to comment 10 regarding possible “more specific determinations”
about the use of proceeds.  Please expand to clarify whether you intend to quantify the
amount of proceeds to be used for each of the purposes to  which you refer.

Capitalization, page 48

6. We note your response to comment 11 but also note that the amounts presented in the
capitalization table do not sum up to $(20,522,150).  Please correct the presentation in
your next amendment.

Comparison of the Three Months Ended March 31, 2017 and 2018, page 56

7. Please revise to clarify and quantify how changes in volume of instruments and
consumables sold affected your results for the three months ended March 31, 2018
compared to the same period in 2017.

Comparison of the Years Ended December 31, 2016 and 2017 , page 57

8. Please revise your disclosure in response to comment 12 to provide quantifications of
revenue increases in volume and price as well as the growth rate in revenue from sales of
instruments v ersus consumables.

Principle Stockholders, page 109

9. While we note your revisions in note 1 in response to comment 19, those revisions appear
to refer only to who disclaims beneficial ownership rather than who has beneficial
ownership.  Please revise to  identify the natural persons who have or share voting and/or
investment po wer over the referenced shares.

R. Erik Holmlin, Ph.D.
Bionano Genomics, Inc.
June 26, 2018
Page 3

 Note 2. Summary of Significant Accounting Policies, page F -8

Revenue Recognition, page F -10

10. We note that your response to comment 22 appears to on ly address software upgrades
and indicates that this is deemed incidental to the hardware.  However, the disclosure on
page 80 indicates that performance enhancements will be delivered on a regular basis
through software and hardware upgrades.  Please revi se further to disclose your
accounting for hardware upgrades.

You may contact Julie Sherman  at (202) 551 -3640 or Brian Cascio, Accounting Branch
Chief , at (202) 551 -3676  if you have questions regarding comments on the financial statements
and related matt ers.  Please contact Heather Percival  at (202) 551 -3498 or Geoff Kruczek, Senior
Attorney, at (202) 551 -3641  with any other questions.

Sincerely,

 /s/ Geoff Kruczek for

Amanda Ravitz
Assistant Director
Office of Electronics and Machinery

cc: James C.  Pennington, Esq.
Cooley LLP