SecProbe.io

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 March 26, 2025

David Wood
General Counsel
Hinge Health, Inc.
455 Market Street, Suite 700
San Francisco, California 94105

 Re: Hinge Health, Inc.
 Registration Statement on Form S-1
 Filed March 10, 2025
 File No. 333-285682
Dear David Wood:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our February 28,
2025 letter

Registration Statement on Form S-1
Prospectus Summary, page 1

1. You state the Hinge Health People in Pain Survey was conducted by you
and a third-
 party research firm in 2022. Please confirm whether you commissioned
this third-
 party research firm for data in use in connection with this offering. If
so, please tell us
 what consideration you gave to filing the third party's consent as an
exhibit to the
 registration statement as required by Section 7 of the Securities Act
and Securities Act
 Rule 436.
2. We note your revised disclosure that the holder of Series E preferred
stock will retain
 rights that could impact the value of your Class A common stock and
impact your
 business and operations. If true, please identify the Series E preferred
stock as Tiger
 Global, a shareholder that currently holds 8.6% of your voting power.
 March 26, 2025
Page 2

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of the Years Ended December 31, 2024 and 2023
Revenue, page 114

3. We note your revenue for the year ended December 31, 2024 increased by
33%
 compared to the year ended December 31, 2023. Please quantify this
increase between
 members from new and existing clients. Further, please consider
expanding your
 discussion to analyze the increase in your member yield. Refer to Item
303(b)(2) of
 Regulation S-K.
Non-GAAP Financial Measures, page 116

4. We continue to consider your response to prior comment 2 and may have
further
 comments.
16. Subsequent Events, page F-38

5. When your preliminary IPO price is known, please provide us with a
breakdown of all
 equity awards granted since January 1, 2025 and leading up to the
preliminary pricing
 of your IPO. This breakdown should list grants in chronological order
including the
 fair value of the underlying common stock used to value such awards as
determined
 by your board of directors. Please reconcile and explain the differences
between the
 fair values of the underlying common stock determined on each grant
date, including
 the difference between the most recent grant date fair value and the
midpoint of your
 offering range. In addition, your disclosure should fully describe the
assumptions
 utilized at the IPO valuation date that are significantly different than
those used in
 the most recent valuation, if material.
General

6. Please provide balanced disclosure in the graphics by disclosing the net
loss for the
 year ended December 31, 2024.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please contact Mariam Mansaray at 202-551-5176 or Jan Woo at
202-551-3453 with
any other questions.

 Sincerely,
 March 26, 2025
Page 3

 Division of Corporation Finance
 Office of Technology
cc: Tad J. Freese
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