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 July 2, 2025

Mark D. Mordell
Chief Executive Offcier
Avidbank Holdings, Inc.
1732 North First Street
6th Floor
San Jose, CA 95112

 Re: Avidbank Holdings, Inc.
 Amendment No. 1 to Draft Registration Statement on Form S-1
 Submitted June 3, 2025
 CIK No. 0001443575
Dear Mark D. Mordell:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our May 9, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form S-1
Summary, page 1

1. We note the response to prior comment 12 and the pie chart on page 7.
With a view to
 clarifying disclosure, advise us of the extent to which borrowers may
fall under more
 than one of the following three categories: Venture Lending, Specialty
Finance and
 Corporate Banking. If material, to provide context for the concentration
in loan and
 borrower characteristics, further clarify how you determine which
category to use. For
 example, we note technology companies appear to be borrowers in all
three
 categories, but it is unclear if the only distinguishing characteristic
for technology
 July 2, 2025
Page 2

 companies in the Venture Lending group is that they are VC-backed.
Alternatively, it
 is unclear if it is sufficient for them to meet the revenue and
profitability
 characteristics ("negative operating cash flows and no record of
profitability") without
 being VC-backed. It is also unclear if there are any technology
companies in the
 Specialty Finance or Corporate Banking groups that could be
"early-stage, growth-
 stage [or] late-stage technology companies."
Specialty Finance Division, page 103

2. We note the revised disclosure that you continue to shift the mix of
Venture Lending
 clients to a larger concentration of expansion and later stage venture
companies,
 "which are typically approaching or have achieved positive operating
cash flows." If
 material, please further clarify the extent of this trend by, for
example, providing an
 approximate percentage of Venture Lending clients that have achieved
positive
 operating cash flows as compared to the previous financial statement
period.
 Please contact John Spitz at 202-551-3484 or Cara Lubit at 202-551-5909
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Craig Miller
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