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November 13, 2023
Linda Ramirez-Eaves
General Counsel
Olink Holding AB (publ)
130 Turner St. Building 2, Suite 230
Waltham, MA 02453
Re:Olink Holding AB (publ)
Schedule 14D-9 Filed October 31, 2023
File No. 005-93360
Dear Linda Ramirez-Eaves:
            We have reviewed your filing and have the following comments.
            Please respond to these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
All defined terms used herein have the same meaning as in your Schedule 14D-9, unless
otherwise indicated.
Schedule 14D-9 Filed October 31, 2023
Identity and Background of Filing Person, page 1
1.We note the disclosure on pages 18 and 20 of the Offer to Purchase that Buyer is not
providing for any guaranteed delivery procedures. Therefore, on page 2 of the Schedule
14D-9, please remove the references to such guaranteed delivery procedures.
2.We note the name and address of Buyer on page 3 of the Schedule 14D-9. Because it is a
co-offeror, please also provide the name and address of Parent. See Item 1003(d) of
Regulation M-A.
Past Contacts, Transactions, Negotiations and Agreements, page 3
3.On page 6 of the Schedule 14D-9, you state that Parent and Olink are party to “certain
commercial arrangements.” Please expand this disclosure to briefly describe the nature of
those commercial arrangements or direct shareholders to another place in the Schedule
14D-9 where this disclosure appears.

 FirstName LastNameLinda Ramirez-Eaves
 Comapany NameOlink Holding AB (publ)
 November 13, 2023 Page 2
 FirstName LastNameLinda Ramirez-Eaves
Olink Holding AB (publ)
November 13, 2023
Page 2
4.Refer to the following statement made on page 7 of the Schedule 14D-9: “Olink’s
executive officers and directors who tender their Offer Securities pursuant to the Offer
will be entitled to receive the same consideration as Olink’s other security holders who
tender Offer Securities pursuant to the Offer . . . .” Consistent with your disclosure on
page 26 of the Schedule 14D-9 (under “Risk of Tender and Support Agreement Parties
Receiving Lower Consideration”), please qualify this statement to indicate that under
certain circumstances parties to the Tender and Support Agreement may receive less
consideration than other security holders who tender Offer Securities pursuant to the
Offer.
Certain Management Projections, page 27
5.Summarize the material assumptions and limitations of the Management Projections.
6.We note that you have not included a reconciliation for the Management
Projections. Please explain why not or revise to do so. See Item 100(a) of Regulation G.
7.Refer to the last sentence in the first full paragraph after the table on page 28 of the
Schedule 14D-9. While the parties and their financial advisors may include cautionary
language regarding reliance on the projections disclosed, it is inappropriate for the party
that prepared the projections to disclaim all responsibility for them. Please revise.
Opinions of Olink's Financial Advisors, page 29
8.Please confirm in your response letter that the Management Projections included in the
Schedule 14D-9 constitute the only projections and forecasts provided by Olink to the
financial advisors. On page 30 of the Schedule 14D-9, we note the reference to additional
information about the “future prospects and operations of Olink” that was provided to J.P.
Morgan. If additional forecasts or projections were provided, please summarize them in a
revised disclosure document.
9.The opinions of both J.P. Morgan and Goldman Sachs state that they may not be
reproduced or referenced without the prior permission of the preparer. The J.P. Morgan
opinion states that it may be reproduced in “any proxy or information statement” but does
not refer to tender offer materials. Please state here, or where appropriate in the offer
materials, that each advisor has consented to the references to its opinion and the filing of
each opinion as an exhibit to the Schedule 14D-9.
10.Expand the disclosure on page 32 of the Schedule 14D-9 to provide further details about
how J.P. Morgan selected the publicly traded companies used in its comparison.
Specifically, explain how the selected companies were considered similar to Olink and
its operations and business, besides being publicly-traded entities.
11.See our last comment above. Similarly, in the following section on page 32 of the
Schedule 14D-9, explain how J.P. Morgan determined that these transactions involved
companies that had an analogous business to Olink (or aspects thereof).

 FirstName LastNameLinda Ramirez-Eaves
 Comapany NameOlink Holding AB (publ)
 November 13, 2023 Page 3
 FirstName LastName
Linda Ramirez-Eaves
Olink Holding AB (publ)
November 13, 2023
Page 3
12.Revise the first sentence under “Miscellaneous” on page 33 of the Schedule 14D-9 to
avoid stating that the summary is not “complete.” While a summary necessarily involves
paring down information, all material aspects of the opinions of both financial advisors’
analyses should be described.
Persons/Assets, Retained, Employed, Compensated or Used, page 39
13.On page 40 of the Schedule 14D-9, please clarify the reference to a “study” performed by
Goldman Sachs.
Additional Information, page 41
14.On page 42 of the Schedule 14D-9, you state that in connection with the Compulsory
Redemption process, among other things, “one arbitrator shall be nominated jointly by the
Minority Shareholders who have not tendered their Offer Securities in the Offer . . . .”
Please revise this statement to include shareholders who have properly withdrawn their
shares tendered in the Offer, or otherwise explain why they would not be included in the
nomination process.
15.Refer to the following statement made on page 43 of the Schedule 14D-9: “If there is a
disagreement between the Parent and Buyer and the Minority Shareholder regarding the
Offer Consideration to be paid in the Compulsory Redemption, the matter is decided by
the Arbitral Tribunal, based on the provisions of the Swedish Companies Act.” Please
elaborate on how the Arbitral Tribunal would determine the proper redemption price
under the Swedish Companies Act in such a dispute and state under what conditions, if
any, that the Arbitral Tribunal may set the redemption price below the highest
consideration offered during the Offer. See Rule 13e-3(g)(1).
16.Refer to the following statement made on page 44 of the Schedule 14D-9: “You should
rely only on the information contained in this Schedule 14D-9, including the annexes and
exhibits included hereto or the information incorporated by reference herein, to vote your
shares at the Combined Meeting.” Please define “Combined Meeting” or delete this term
and revise the above statement.
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to Christina Chalk at 202-551-3263, Shane Callaghan at 202-
330-1032, or Eddie Kim at 202-679-6943.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions