SecProbe.io

March 2, 2015

Eric J. Rey
President and  Chief  Executive Officer
Arcadia Biosci ences, Inc.
202 Coust eau Place, Suite 200
Davis, CA 95618

Re: Arcadia Biosci ences, Inc.
Registration Statement on Form S-1
Filed February 17, 2015
File No. 333-202124

Dear Mr. Rey:

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

Please respond to this letter by amending your registration statement and providing the
requested information .  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 reviewin g any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Exhibit 5.1

1. Please file the legal opinion as Exhibit 5.1 prior to requesting effectiveness.

Index to Consoli dated Financial Statements, page F -1

2. Please update your financial statements pursuant to Rule 3 -12(b) and (d) of
Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and a dequacy of the disclosures they have made.

Eric J. Rey
Arcadia Biosciences, Inc.
March 2, 2015
Page 2

 Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement, please provide  a written statement from the company
acknowledging that:

 should t he Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delega ted authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding reque sts for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securitie s Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effectiv e date of the
registration statement.

You m ay contact Stephen Kim  at (202)  551-3291  or Doug Jones at (202)  551-3309 if
you have questions r egarding comments on the financial statements and related matte rs.  Please
contact Julie Griffith at (202) 551-3267 or  me at (202) 551-3611 with a ny other  questions.

Sincerely,

/s/ A.N. Parker

Anne  Nguyen Parker
Assistant Di rector

Cc: Karen Dempsey
Orrick, Herrington & Sutclif fe LLP