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CORRESP
 1
 filename1.htm

 CORRESP

 March 10, 2025

 140 Scott Drive

 Menlo Park, California 94025

 Tel: +1.650.328.4600 Fax: +1.650.463.2600

 www.lw.com

 FIRM / AFFILIATE OFFICES

 Austin

 Milan

 Beijing

 Munich

 Boston

 New York

 Brussels

 Orange County

 Century City

 Paris

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 Riyadh

 Dubai

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 Düsseldorf

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 Houston

 Tel Aviv

 London

 Tokyo

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 Washington, D.C.

 Madrid

 VIA EDGAR United
States Securities and Exchange Commission Division of Corporation Finance
 100 F Street, N.E. Washington, D.C. 20549-6010

 Attention:  
 Ryan Rohn
 Stephen Krikorian Mariam
Mansaray Jan Woo

 Re:
 Hinge Health, Inc.
 Amendment No. 2 to Draft Registration Statement on Form S-1
 Submitted February 14, 2025
 CIK No. 0001673743 Ladies and
Gentlemen: Hinge Health, Inc. (the “ Company ”) has filed with the U.S. Securities and Exchange Commission (the
“ Commission ”) on the date hereof a Registration Statement on Form S-1 (the “ Registration Statement ”). The Company previously submitted to the
Commission a draft Registration Statement on Form S-1 on a confidential basis under the Jumpstart Our Business Startups Act on November 15, 2024 (the “ Draft Submission ”), as most
recently amended by Amendment No. 2 to the Draft Submission submitted on February 14, 2025 (“ Amendment No. 2 ”). The Registration Statement has been revised to reflect the
Company’s responses to the comment letter to Amendment No. 2 received on February 28, 2025 from the staff of the Commission (the “ Staff ”), and we are hereby providing the Company’s responses to the
Staff’s letter. For ease of review, we have set forth below each of the numbered comments of the Staff’s letter in bold type
followed by the Company’s responses thereto. Amendment No. 2 to Draft Registration Statement on Form
 S-1 Risk Factors
 A substantial portion of our client relationships are contracted through a limited number of health plans and other partners, page 28

 March 10, 2025
 Page 2

 1.
 We note your revised disclosure in response to prior comment 2 that client contracts through your top three
partners, which are all large national health plans, accounted for 43% of your revenue for the year ended December 31, 2023. Please disclose the amount of revenue attributable to each of your top three partners. Disclose the material terms of
the agreements with your top three partners, including the identity of the partners and termination provisions. We note that your partnership agreements may be terminated for “various reasons” after “a specified period.” Disclose
the expiration date of the agreements, the conditions under which the agreements may be terminated, and whether the “specified period” has passed such that the contacts are terminable for convenience by your partners.
 Response : The Company respectfully acknowledges the Staff’s comment and has revised page 30 of the
Registration Statement to disclose the names of its top three partners, the amount of revenue contracted through each of the three partners during 2024 and 2023, and detail regarding the material terms of its agreements with each of the three
partners. Non-GAAP Financial Measures
 Non-GAAP Loss from Operations and Operating Margin, page 111

 2.
 We note from your response to prior comment 1 that the release of TrueMotion, your AI-powered motion tracking technology, was intended to replace wearable sensors and allow for members to use their personal devices. Please further explain why the shift away from providing kits with tablets and
wearable sensors is considered to be a strategic decision and describe how this shift changes the nature of the services provided through your platform.
 Response : The Company respectfully acknowledges the Staff’s comment and has revised pages 106 and 107 of the Registration Statement
to describe the strategy behind the decision to shift to AI-powered motion tracking technology and how this decision improves the Company’s delivery of care and the member experience, opens up new
offerings and capabilities, and improves efficiency, thereby enabling the Company to scale and allocate greater capital resources to develop its business.
 The Company’s decision to shift to AI-powered motion tracking technology and stop providing kits
with tablets and wearable sensors enables the Company to focus on delivering scalable and personalized MSK care and making the Company’s programs easily accessible and available to as many members and potential members as possible. This marks a
significant shift for the Company as the use of AI-powered motion tracking technology enables the Company to improve the delivery of care through its programs and to develop programs for smaller affected
areas, such as the hand and wrist, where sensors were not effective. The Company believes the use of TrueMotion results in improved
delivery of care and a better member experience, beyond what was possible with sensors, because the use of AI-powered motion tracking technology increases convenience, accessibility, and adherence. TrueMotion
allows members to access the Company’s programs and care any time without the use of additional hardware beyond a member’s personal device. As a result, member engagement and satisfaction improved after the strategic transition. Moreover,
TrueMotion measures three-dimensional human motion across more than 100 unique points on a member’s body, which is more precise than sensors, as sensors were historically only attached to one or two joints of the body. As a result, members can
be confident in their movements as the Company’s technology provides more precise exercise form guidance and correction through AI-powered motion tracking, something that was significantly more limited
with sensors. With AI-powered motion tracking technology, the information gathered in a member’s exercise therapy session is

 March 10, 2025
 Page 3

then fed back into the Company’s data repository. This data allows the care team to improve the member’s care plan going forward, by adjusting exercises that the member may not have
been successful in completing or increasing difficulty for exercises that were too easy. This data also improves the Company’s AI and ML algorithms that drive the TrueMotion technology and the AI / machine learning
(“ ML ”) that is used to develop member care plans, creating a positive feedback loop that continuously improves the Company’s platform and programs. AI-powered motion tracking
technology also opens new opportunities for the Company to leverage AI / ML and augmented reality for new use cases, which could include voice control, where the member can speak back to the platform, or automating physical exams, where the
technology could take the member through a series of exercises while evaluating their mobility, range of motion, and overall performance, and sensing asymmetry that would be difficult to see with the human eye. These capabilities are not possible
with sensors. Moreover, this is a strategic decision for the Company’s business because it lowers the Company’s variable cost
of providing its programs since the Company no longer provides kits with tablets and wearable sensors. The Company believes this was a major shift that provides the Company with a competitive advantage because it can scale more rapidly and allocate
greater capital to develop its business. * * *

 March 10, 2025
 Page 4

 We hope the foregoing answers are responsive to your comments. Please do not hesitate to
contact me by telephone at (650) 463-3060 with any questions or comments regarding this correspondence.

 Very truly yours,

 /s/ Tad J. Freese

 Tad J. Freese of LATHAM & WATKINS
LLP

 cc:
 (via email)
 Daniel Perez, Hinge Health, Inc.
 David Wood, Hinge Health, Inc.
 James Budge, Hinge Health, Inc.
 Erica Kassman, Latham & Watkins LLP
 Alan F. Denenberg, Davis Polk & Wardwell LLP