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Cheap Stock Letter

 *FOIA Confidential Treatment Request*
Confidential Treatment Requested by

SI-BONE, Inc.
in connection with Registration Statement
on Form S-1 filed on September 20, 2018

 Matthew B. Hemington

+1 650 843 5062

hemingtonmb@cooley.com

 September 26, 2018

 U.S.
Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Mail Stop 3720

Washington, DC 20549

Attn:
 Ms. Amanda Ravitz, Assistant Director

Mr. Thomas Jones, Attorney Advisor

Mr. Kevin Kuhar, Staff Accountant

RE:
 SI-BONE, Inc.
Registration Statement on Form S-1
Filed on September 20, 2018
File No. 333-227445

Ladies and Gentlemen:

 On behalf of SI-BONE, Inc. (the “Company”), we are supplementally providing the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) with information regarding the proposed price range of the shares of the Company’s common stock to be offered in the proposed initial public offering (the “IPO”) pursuant to the
Company’s Registration Statement on Form S-1, (File No. 333-227445), filed with the Commission on September 20, 2018 (the “Registration
Statement”), as well as historical information with respect to the estimated fair value of its common stock since December 31, 2016.

Confidential Treatment Request

 Due to the commercially
sensitive nature of information contained in this letter, the Company hereby requests, pursuant to 17 C.F.R. §200.83, that certain portions of this letter be maintained in confidence, not be made part of any public record and not be disclosed
to any person. The Company has filed a separate copy of this letter, marked to show the portions redacted from the version filed via EDGAR and for which the Company is requesting confidential treatment. In accordance with 17 C.F.R.
§200.83(d)(1), if any person (including any governmental employee who is not an employee of the Commission) should request access to or an opportunity to inspect this letter, we request that we be immediately notified of any such request, be
furnished with a copy of all written materials pertaining to such request (including, but not limited to, the request itself) and be given at least ten business days’ advance notice of any intended release so that the Company may, if it deems
it to be necessary or appropriate, pursue any remedies available to it. In such event, we request that you telephone the undersigned at 650-843-5062 rather than rely on
the U.S. mail for such notice.

 [*] Certain confidential information contained in this letter, marked by brackets, has been omitted and filed separately
with the Commission pursuant to 17 C.F.R. §200.83

 U.S. Securities and Exchange Commission

September 26, 2018

  Page
 2

 IPO Price Range

The Company supplementally advises the Staff that the Company preliminarily estimates a price range of $[*] to $[*] per share (the “Price
Range”) for its IPO, which does not take into account a reverse stock split of the Company’s capital stock (the “Reverse Stock Split”). The preliminary Price Range has been estimated based, in part, upon
current market conditions, the Company’s financial condition and prospects and input received from the lead underwriters, including discussions that took place on September 23, 2018 between senior management of the Company and
representatives of Morgan Stanley & Co. LLC and Merrill Lynch, Pierce, Fenner & Smith Incorporated. Prior to September 23, 2018, the Company and underwriters had not had any specific discussions regarding the Price Range. In
determining the Price Range, the underwriters focused on a number of valuation methodologies to triangulate valuation, including a discounted cash flow analysis and relevant trading multiples.

The Company expects to include a two-dollar price range and the size of the Reverse Stock Split in an amendment to the
Registration Statement that will be filed shortly before the commencement of the Company’s roadshow. The Company is providing this information to the Staff supplementally to facilitate your review process. The share numbers, exercise prices and
fair values per share have not been adjusted in this letter to reflect the Reverse Stock Split.

 Historical Fair Value Determination and Methodology

 As stated on page 83 of the Registration Statement, stock-based compensation expense related to stock options granted to employees is measured at the
date of grant based on the fair value of the award, net of estimated forfeitures, through December 31, 2017. The Company’s stock-based compensation is reduced for the estimated forfeitures at the date of grant and revised, if necessary, in
subsequent periods if actual forfeitures differ from those estimates. Pages F-33 to F-34 of the Registration Statement describe the Company’s use of the
Black-Scholes option-pricing model for these purposes and describe and quantify the significant assumptions used during 2017 and the six months ended June 30, 2017 and June 30, 2018.

The Company’s Board of Directors (the “Board”) intended all options granted to be exercisable at a price per share not less than
the per share fair value of the common stock underlying those options on the date of grant. The estimated fair value of the common stock underlying stock options was determined at each grant date by the Board and was supported by periodic
independent third-party valuations. In contrast to the metrics used by the underwriters in determining the Price Range, the valuations of common stock were determined in accordance with the guidelines outlined in the American Institute of Certified
Public Accountants Accounting and Valuation Guide, Valuation of Privately-Held-Company Equity Securities Issued as Compensation as described herein and on page 84 of the Registration Statement. As discussed below, the methodologies used by
the Company and the third-party valuation firm to determine the fair value of the Company’s equity included Income Approach and Market Approach methodologies. Once the equity value as a whole is calculated, it needs to be distributed among the
various equity classes. To value the different classes of equity, a hybrid method was employed. This method is a hybrid between the Probability-Weighted Expected Return Method (“PWERM”) and the Option Pricing Method
(“OPM”). The PWERM is focused on future exit events and their allocation to each class of equity. In application of the PWERM, the value of the common stock assumed IPO exit events based on the expected pricing and timing of
the anticipated IPO; upon the IPO the preferred stock are mandatorily converted to common stock and the preferred and common stock have equal value. An OPM, which treats common stock and preferred stock as call options on the
Company’s equity value, with exercise prices based on the liquidation preferences of the preferred stock, was also employed. This approach was used to estimate the value of the common stock, assuming the IPO does not occur. The resulting common
stock under each scenario was then weighted by their respective probabilities.

 [*] Certain confidential information contained in this letter, marked by
brackets, has been omitted and filed separately with the Commission pursuant to 17 C.F.R. §200.83

 U.S. Securities and Exchange Commission

September 26, 2018

  Page
 3

 The assumptions used in each valuation model to determine the fair value of the Company’s common stock
as of the grant date of each option are based on numerous objective and subjective factors, combined with management judgment, including the following:

•
 equity market conditions affecting comparable public companies, as reflected in comparable companies’
market multiples, initial public offering valuations and other metrics;

•
 the estimated likelihood of achieving a liquidity event for the shares of the Company’s common stock, such
as an IPO or an acquisition of the Company, given prevailing market conditions and other contingencies affecting the probability or potential timing of such an event;

•
 the terms of the preferred stock relative to the terms of the Company’s common stock; and

•
 the fact that the options and the Company’s common stock are illiquid securities of a private company.

 Determination of Estimated Value

The Company was founded in 2008 and has experienced significant challenges at certain points in time that impacted its estimated enterprise value, including
primarily challenges related to surgeon reimbursement for the implantation procedure to place the Company’s iFuse implants. Prior to the Company’s launch of iFuse in 2009, Medicare and most U.S. private insurance companies reimbursed
surgeons routinely for sacroiliac joint fusions, which were primarily open procedures. However, effective July 1, 2013, the American Medical Association’s (“AMA”) Editorial Panel effectively restricted reimbursement
for minimally invasive sacroiliac joint fusion because it considered the published clinical evidence supporting the new procedure at the time to be inadequate.

Subsequently, as a result of the growing number of published clinical studies demonstrating the effectiveness and safety of iFuse, along with the support of
several professional medical specialty societies and leading academic surgeons, the AMA Editorial Panel established a new Category I (non-experimental) reimbursement code for minimally invasive sacroiliac
joint fusion surgery, effective January 1, 2015. However, the new code did not immediately lead to positive coverage decisions by payors—in many cases, the payors wanted additional published evidence before deciding to cover the procedure.
As a result, positive reimbursement decisions covering the procedure have occurred over the last few years, and some payors are still in the process of making decisions based on the most recent evidence.

Because of these challenges, the Company’s estimated equity value has fluctuated over the last few years. This fluctuation is evident in sales of the
Company’s preferred stock. From April 2014 to June 2015, the Company issued and sold an aggregate of 59.7 million shares of its Series 6 preferred stock at $0.92 per share, for aggregate consideration of $54.7 million. However, from
June 2016 to March 2017, in light of the delay in the Company’s proposed initial public offering, in order to fund its ongoing operations, the Company issued and sold an aggregate of 46.4 million shares of its Series 7 preferred stock at
$0.56 per share, a 39% reduction from the prior financing round, for aggregate consideration of $25.9 million.

 [*] Certain confidential information
contained in this letter, marked by brackets, has been omitted and filed separately with the Commission pursuant to 17 C.F.R. §200.83

 U.S. Securities and Exchange Commission

September 26, 2018

  Page
 4

 In addition, the Company has significant indebtedness, and as of June 30, 2018, had $38.8 million
of long-term borrowings and cash and cash equivalents of only $16.2 million. Also, as of June 30, 2018, the holders of the Company’s preferred stock held significant liquidation preferences of $119.2 million, and certain holders
also have the right to participate with the holders of common stock after the payment of their liquidation preference.

 The Company originally
confidentially submitted a draft registration statement to the Commission in August 2015, which offering was subsequently delayed following the submission of an amendment in November 2015. In March 2017, after completing its most recent sale of
Series 7 preferred stock, the Company re-initiated the IPO process and re-submitted a draft registration statement, but in the third quarter of 2017, the Company again
determined to delay the IPO process. In July 2018, the Company re-initiated the IPO process and again re-submitted a draft registration statement to the Commission. The
Company has publicly disseminated all of its previously submitted draft registration statements.

 The independent third-party valuations considered the
valuation approaches as follows:

 Income Approach

The income approach recognizes that the value of an investment is premised on the receipt of future economic benefits and the estimate of the future cash flows
that a company will generate. The income approach is estimated based on the present value of future cash flows during the term of a project period plus the terminal value; this approach generally used a projection period term of 3 to 36 months from
the valuation date.

 Based on the Company’s stage, its operating history, and the level of variability and uncertainty of forecasted future cash
flows, an income approach was not employed in valuations prior to 2018.

 Market Approach

The market approach assumes that businesses operating in the same industry will share similar characteristics and therefore, a comparison of the business to
similar businesses whose financial information is publicly available may provide a reasonable basis to estimate a subject business’s value. The Company evaluated two principal methodologies under this approach:

•
 the guideline public company methodology (“GPCM”); and

•
 the guideline M&A transaction company methodology (the “GMAC”).

 The GPCM derives valuation multiples from the stock prices of publicly traded companies for which the Company developed a list of peer
companies which were consistently used during the periods discussed herein.

 The GMAC derives valuation multiples from prices at which entire companies
are acquired in a merger or acquisition. When employed, the GMAC was used to derive additional insights into valuation multiples and to assess the reasonability of the results from the GPCM, but this method was not a primary indicator of value and
was not assigned any weight in concluding on the Company’s enterprise value.

 [*] Certain confidential information contained in this letter, marked
by brackets, has been omitted and filed separately with the Commission pursuant to 17 C.F.R. §200.83

 U.S. Securities and Exchange Commission

September 26, 2018

  Page
 5

 The GPCM was used because it was determined to be the most relevant in capturing the value of the Company at
current state and on a go-forward basis based upon comparability of relevant publicly available information.

Allocation of Estimated Value to Outstanding Securities

Once the value of the enterprise was estimated, it was then allocated among the various classes of equity.

Option Pricing Method

 The allocation of Company value to
each part of the Company’s capital structure, including common stock, was done based on the OPM. This method treated the rights of the holders of preferred and common shares as equivalent to call options on portions of the value of the Company
above certain breakpoints of value based upon the repayment of the debt of the Company and payment of the liquidation preferences of the holders of preferred shares, as well as the rights of holders of different equity securities to participation in
excess proceeds and deemed conversion to common stock. The estimated value of the common stock was determined by estimating the value of its portion of each of these call option rights. The OPM considered a range of possible future outcomes. The OPM
backsolve method infers equity value implied by a financing transaction; this methodology was employed when there was a recent financing transaction on an arms-length basis.

Probability Weighted Expected Return Method

 Under the
PWERM, equity value was estimated based upon analysis of future values of the Company under varying scenarios; probabilities were ascribed to these scenarios based upon expected future outcomes. This method involved a forward-looking analysis of the
possible future outcomes of the Company. Discrete future outcomes considered under the PWERM included an initial public offering scenario. The IPO scenario relied on a Common Stock Equivalent (“CSE”) allocation methodology,