SecProbe.io

CORRESP
1
filename1.htm

    March 4, 2026

    VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    SOPHiA GENETICS SA

Registration Statement on Form F-3

Registration No. 333-293970

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended,
we hereby request acceleration of the effective date of the Registration Statement on Form F-3 (File No. 333-293970) (as amended, the
“Registration Statement”) of SOPHiA GENETICS SA. We respectfully request that the Registration Statement be declared effective
as of 4:00 p.m., Eastern time, on March 6, 2026 or as soon as practicable thereafter.

Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling Sierra Acosta at (212) 450-3504.

Thank you for your assistance in this matter.

Sincerely,

    SOPHiA GENETICS SA

    By:
    /s/ Daan van Well

    Name:
    Daan van Well

    Title:
    Chief Legal & Regulatory Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                           March 4, 2026

Jurgi Camblong
Chief Executive Officer
SOPHiA GENETICS SA
La Pi  ce 12
CH-1180 Rolle
Switzerland

       Re: SOPHiA GENETICS SA
           Registration Statement on Form F-3
           Filed March 3, 2026
           File No. 333-293970
Dear Jurgi Camblong:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

       Please contact Jan Woo at 202-551-3453 with any questions.

                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:    Steven Glendon
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 August 13, 2025

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

 Re:
 SOPHiA GENETICS SA
Registration Statement on Form F-3
Registration No. 333-289266

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities Act of 1933, as amended,
we hereby request acceleration of the effective date of the Registration Statement on Form F-3 (File No. 333-289266) (as amended, the
"Registration Statement") of SOPHiA GENETICS SA. We respectfully request that the Registration Statement be declared effective
as of 4:00 p.m., Eastern time, on August 15, 2025 or as soon as practicable thereafter.

 Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling Sierra Acosta at (212) 450-3504.

 Thank you for your assistance in this matter.

 Sincerely,

 SOPHiA GENETICS SA

 By:
 /s/ Daan van Well

 Name:	Daan van Well

 Title:	Chief Legal & Regulatory Officer

CORRESP
 1
 filename1.htm

 August 13, 2025

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

 Re:
 SOPHiA GENETICS SA
Registration Statement on Form F-3
Registration No. 333-289270

 Ladies and Gentlemen:

 In accordance with Rule 461 under the Securities Act of 1933, as amended,
we hereby request acceleration of the effective date of the Registration Statement on Form F-3 (File No. 333-289270) (as amended, the
"Registration Statement") of SOPHiA GENETICS SA. We respectfully request that the Registration Statement be declared effective
as of 4:00 p.m., Eastern time, on August 15, 2025 or as soon as practicable thereafter.

 Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling Sierra Acosta at (212) 450-3504.

 Thank you for your assistance in this matter.

 Sincerely,

 SOPHiA GENETICS SA

 By:
 /s/ Daan van Well

 Name:	Daan van Well

 Title:	Chief Legal & Regulatory Officer

<DOCUMENT>
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<FILENAME>filename2.txt
<TEXT>
 August 12, 2025

Jurgi Camblong
Chief Executive Officer
Sophia Genetics SA
La Pi ce 12
CH-1180 Rolle
Switzerland

 Re: Sophia Genetics SA
 Registration Statement on Form F-3
 Filed August 5, 2025
 File No. 333-289266
Dear Jurgi Camblong:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Alexandra Barone at 202-551-8816 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: David Li, Esq.
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 12, 2025

Jurgi Camblong
Chief Executive Officer
Sophia Genetics SA
La Pi ce 12
CH-1180 Rolle
Switzerland

 Re: Sophia Genetics SA
 Registration Statement on Form F-3
 Filed August 5, 2025
 File No. 333-289270
Dear Jurgi Camblong:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Alexandra Barone at 202-551-8816 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: David Li, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
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    July 22, 2024

    VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    SOPHiA GENETICS SA

Registration Statement on Form F-3

Registration No. 333-280060

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended,
we hereby request acceleration of the effective date of the Registration Statement on Form F-3 (File No. 333-280060) (as amended, the
“Registration Statement”) of SOPHiA GENETICS SA. We respectfully request that the Registration Statement be declared effective
as of 4:00 p.m., Eastern time, on July 24, 2024, or as soon as practicable thereafter.

Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling David Li at (212) 450-3861.

Thank you for your assistance in this matter.

Sincerely,

    SOPHiA GENETICS SA

    By:
    /s/ Daan van Well

    Name:	Daan van Well

    Title:	Chief Legal Officer

United States securities and exchange commission logo
May 18, 2023
Ross Muken
Chief Financial Officer
SOPHiA GENETICS SA
185 Dartmouth Street Floor 5
Boston, MA 02116
Re:SOPHiA GENETICS SA
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed March 7, 2023
File No. 001-40627
Dear Ross Muken:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
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    May 17, 2023

    Re:
    SOPHiA GENETICS SA

Form 20-F for the Fiscal Year Ended December 31, 2022

Form 6-K furnished May 9, 2023

File No. 001-40627

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mary Mast and Frank Wyman

Dear Ms. Mast and Mr. Wyman:

SOPHiA GENETICS SA (the “Company”) submits this letter to
set forth the Company’s response to the comment provided by the staff (the “Staff”) of the U.S. Securities and Exchange
Commission (the “Commission”) contained in the Staff’s letter dated May 11, 2023.

Form 6-K
furnished May 9, 2023

Exhibit 99.3

Reconciliation of IFRS to Adjusted IFRS Statement of Profit and Loss, page 11

 1. Your non-IFRS presentation appears to represent a full consolidated statement of profit and loss. Please tell us why you believe your
presentation is consistent with Question 102.10(a) through (c) of the Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures.

Response: The Company acknowledges the Staff’s comment.
The Company respectfully advises the Staff that the Form 6-K furnished on May 9, 2023 is not incorporated by reference into any registration
statement, prospectus or annual report. In the Commission’s final rule regarding Conditions for Use of Non-GAAP Financial Measures
(Release Nos. 33-8176; 34-47226), the Commission noted that materials submitted to the Commission on Form 6-K, while subject to Regulation
G, are not subject to Item 10 of Regulation S-K, under which the equal-or-greater prominence requirement to which Question 102.10(a) through
(c) of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures are issued by the Staff, unless the information in
the Form 6-K is incorporated by reference into a registration statement, prospectus or annual report. Nonetheless, the Company has considered
the Staff’s comment and Question 102.10(a) through (c) of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures
and informs the Staff that, in future submissions to the Commission, the Company will present non-IFRS financial measures separately,
including reconciliation of each such measure to the most comparable IFRS measure, and in a manner not resembling a full consolidated
statement of profit and loss.

* * *

Please do not hesitate to contact Yasin Keshvargar at (212) 450-4839
or Deanna L. Kirkpatrick at (212) 450-4135 if you have any questions regarding the foregoing or if we can provide any additional information.

Very truly yours,

/s/ Daan van Well

Daan van Well

Chief Legal Officer

United States securities and exchange commission logo
May 11, 2023
Ross Muken
Chief Financial Officer
SOPHiA GENETICS SA
185 Dartmouth Street Floor 5
Boston, MA 02116
Re:SOPHiA GENETICS SA
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed March 7, 2023
Form 6-K furnished May 9, 2023
File No. 001-40627
Dear Ross Muken:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to the comment, we may have additional comments.
Form 6-K furnished May 9, 2023
Exhibit 99.3
Reconciliation of IFRS to Adjusted IFRS Statement of Profit and Loss, page 11
1.Your non-IFRS presentation appears to represent a full consolidated statement of profit
and loss. Please tell us why you believe your presentation is consistent with Question
102.10(a) through (c) of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.

 FirstName LastNameRoss Muken
 Comapany NameSOPHiA GENETICS SA
 May 11, 2023 Page 2
 FirstName LastName
Ross Muken
SOPHiA GENETICS SA
May 11, 2023
Page 2
            In closing, 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.
            You may contact Mary Mast at (202) 551-3613 or Frank Wyman at (202) 551-3660 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

United States securities and exchange commission logo
August 11, 2022
Jurgi Camblong
Chief Executive Officer
SOPHiA GENETICS SA
Rue du Centre 172
CH-1025 Saint-Sulpice
Switzerland
Re:SOPHiA GENETICS SA
Registration Statement on Form F-3
Filed August 9, 2022
File No. 333-266704
Dear Dr. Camblong:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Jordan Nimitz at 202-551-5831 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences

CORRESP
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    August 11, 2022

    VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Jordan Nimitz

    Re:
    SOPHiA GENETICS SA

Registration Statement on Form F-3

Registration No. 333-266704

Dear Ms. Nimitz:

In accordance with Rule 461 under the Securities Act of 1933, as amended,
we hereby request acceleration of the effective date of the Registration Statement on Form F-3 (File No. 333-266704) (the “Registration
Statement”) of SOPHiA GENETICS SA. We respectfully request that the Registration Statement be declared effective as of 4:00 p.m.,
Eastern time, on August 15, 2022, or as soon as practicable thereafter.

Once the Registration Statement has been declared effective, please
orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling David Li at (212) 450-3861.

Thank you for your assistance in this matter.

Sincerely,

    SOPHiA GENETICS SA

    By:
    /s/ Daan van Well

    Name:
    Daan van Well

    Title:
    Chief Legal Officer

CORRESP
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CORRESP

 July 20, 2021

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Attention: Alan Campbell

Re:
 SOPHiA GENETICS SA

Registration Statement on Form F-1 (File
No. 333-257646)

 Request for Acceleration

Ladies and Gentlemen:

 Pursuant to Rule 460 of the General Rules
and Regulations under the Securities Act of 1933, as amended, we wish to advise that as of the date hereof, approximately 2,850 copies of the Preliminary Prospectus dated July 19, 2021 were distributed to prospective underwriters, institutional
investors and prospective dealers in connection with the above-captioned Registration Statement.

 We wish to advise you that the participating
underwriters have informed us that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m.
Eastern Time, on Thursday, July 22, 2021 or as soon thereafter as practicable.

 [Signature page follows]

 Very truly yours,

J.P. Morgan Securities LLC

 Morgan Stanley & Co. LLC

 Cowen and Company, LLC

 Credit Suisse Securities (USA) LLC

 As representatives of the Underwriters

By:

J.P. Morgan Securities LLC

By:

/s/ David Ke

Name:

David Ke

Title:

Managing Director

By:

Morgan Stanley & Co. LLC

By:

/s/ Kalli Dircks

Name:

Kalli Dircks

Title:

Managing Director

By:

Cowen and Company, LLC

By:

/s/ James Streator, III

Name:

James Streator, III

Title:

Managing Director

By:

Credit Suisse Securities (USA) LLC

By:

/s/ John Hoffman

Name:

John Hoffman

Title:

Managing Director, ECM

 [Signature Page to SOPHiA GENETICS SA Acceleration Request]

CORRESP
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CORRESP

 July 20, 2021

 VIA
EDGAR

 Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

Re:
 SOPHiA GENETICS SA (the “Company”)

Registration Statement on Form F-1

Registration No. 333-257646

Attention: Alan Campbell

 Dear Mr. Campbell:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant hereby requests that the effective date for the Registration
Statement referred to above be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time on July 22, 2021 or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Securities
and Exchange Commission. By separate letter, the underwriters of the issuance of the securities being registered join in this request for acceleration.

Please do not hesitate to contact Deanna L. Kirkpatrick of Davis Polk & Wardwell LLP at (212) 450-4135 or
deanna.kirkpatrick@davispolk.com with any questions with respect to this letter.

Sincerely,

SOPHiA GENETICS SA

By:

 /s/ Ross Muken

Name:

Ross Muken

Title:

Chief Financial Officer

CORRESP
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CORRESP

 Davis Polk & Wardwell LLP

450 Lexington Avenue

 New York, NY 10017

davispolk.com

 FOIA Confidential Treatment Request

Pursuant to Rule 83 by SOPHiA GENETICS SA

July 7, 2021

Re:
 SOPHiA GENETICS SA

Registration Statement on Form F-1

Filed July 2, 2021

 CIK
No. 0001840706

 File No. 333-257646

Jenn Do

 Brian Cascio

Division of Corporation Finance, Office of Life Sciences

 U.S.
Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549-3628

 Dear Ms. Do and
Mr. Cascio,

 On behalf of SOPHiA GENETICS SA (the “Company”), we are providing the information that follows to the Staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) in response to Comment 19 contained in the Staff’s letter dated June 22, 2021 (the “Comment Letter”) relating to the Company’s Draft
Registration Statement on Form F-1, confidentially submitted on May 24, 2021 (the “Registration Statement”), in connection with the proposed initial public offering of the Company’s
ordinary shares (the “Offering”).

 The response and information below are based on information provided to us by the Company. For convenience,
the Staff’s comment is repeated below in italics, followed by the Company’s response to the comment. Capitalized terms used but not defined herein are used herein as defined in the Registration Statement. On June 30, 2021, the Company
effected a one-to-20 share split of all issued shares (the “Share Split”). For the Staff’s convenience, all shares and per share amounts have been
adjusted to reflect the Share Split.

 19. We note from page F-41 that the weighted average fair
value of options granted in 2020 under the 2019 ISOP was $34.97 per share and from page F-39 that the weighted average exercise price of such options was $84.48 per share, which appears more consistent with
the range of share prices of options granted in 2020 under this ISOP of $87.29-$97.31 per share (page F-40). Please explain the significant difference between the
aforementioned weighted average fair value and weighted average exercise price. Once you have an estimated offering price or range, please explain to us the reasons for any differences between the recent valuations of your common stock leading up to
the initial public offering and the estimated offering price.

 The Staff’s comment consists of two parts: (i) the relationship between the fair
value of options granted in 2020, the exercise price of such options and the fair value of the ordinary shares underlying such options, and (ii) the relationship between the fair value of the ordinary shares underlying recently granted options
and the estimated initial public offering price. The following response includes background information regarding the Company’s practices with respect to share-based compensation and then responds separately to the two parts of the Staff’s
comment, explaining first the method used to value options and the methods used to value the ordinary shares underlying options and then presenting factors that have affected share valuations.

 Jenn Do

 Brian Cascio

Division of Corporation Finance,

 Office of Life Sciences

U.S. Securities and Exchange

 Commission

 Background Regarding the Company’s Practices Relating to Share-Based Compensation

The Company has two share-based compensation plans, both based on ordinary shares: the 2013 Incentive Share Option Plan (“2013 ISOP”) and the 2019
Incentive Share Option Plan (“2019 ISOP”). Share options were granted until September 2019 under the 2013 ISOP and thereafter under the 2019 ISOP. The Company has made incentive plan awards throughout the course of its fiscal year, such as
upon the hiring of new employees and/or upon annual performance reviews.

 As set forth below, the Company used the Black-Scholes option pricing model to
value its options. A key input to this model is the fair value of the underlying shares. For options granted in 2020 before June 25, 2020, the Company used the fair value of the underlying shares at December 31, 2019, which it derived by
applying the income approach combined with the option pricing method (“OPM”). For options granted in 2020 on or after June 25, 2020, the Company used the fair value of the underlying shares at September 30, 2020, based on the
Series F financing that closed in two tranches occurring in June and September 2020, which it derived by applying the backsolve method in the context of the OPM. Finally, for options granted in the first three months of 2021, the Company used the
fair value of the underlying shares at December 31, 2020, which it derived by applying the income approach combined with the Hybrid Method which considered both an OPM and a near term IPO scenario. The Company believes that the application of
these recognized methods and approaches both supports the cost of options used to determine share-based compensation, and, considered together with the elimination of the significant liquidation preferences enjoyed by the preferred shares as part of
the share capital reorganization to be effected in connection with this Offering, the fact that key value inflection points that significantly increased the Company’s value did not occur until the second quarter of 2021, and certain other
factors customary to an initial public offering, explains the difference between the historical valuation of the Company’s ordinary shares for the purpose of its share-based compensation and the estimated price range of the Offering.

Methods of Determining Historical Fair Value of Shares and Share Options

The Company’s accounting treatment for share-based compensation is primarily contained in note 25, “Share-based compensation”, of its audited
consolidated financial statements (the “Financial Statements”) that form part of the prospectus contained in the Registration Statement.

 As
there has been no public market for the Company’s ordinary shares since its inception, the Company’s Board of Directors has engaged independent third-party valuation specialists to assist them in determining the estimated fair value of the
Company’s share options and of the underlying ordinary shares using methods, approaches and assumptions consistent with the American Institute of Certified Public Accountants’ (the “AICPA”) Audit and Accounting Practice Aid
Series: Valuation of Privately-Held-Company Equity Securities Issued as Compensation. There were various objective and subjective factors that the Company believed were relevant in determining the valuation methods to be applied and in estimating
the fair value of its ordinary shares and of its share options at each grant date, including:

•

 the Company’s financial position, including cash and cash equivalents, and its historical and forecasted
performance and operating results, including cash flow forecasts;

•

 the prices at which the Company sold preferred shares during the relevant period;

•

 the rights and preferences of preferred shares relative to those of ordinary shares, including the right to
liquidation payments in preference to holders of ordinary shares in the event of a liquidation, which will be distributed to shareholders in the following order (which, for the avoidance of doubt, would not be applicable in the Offering):

i.
 to the holders of Series F preferred shares in an amount equal to the higher of (i) the pro rata share of
the liquidation proceeds and (ii) the subscription price paid for the Series F preferred shares; then

2

 Jenn Do

 Brian Cascio

Division of Corporation Finance,

 Office of Life Sciences

U.S. Securities and Exchange

 Commission

ii.
 subject to the liquidation preference above, to the holders of Series E preferred shares, in an amount equal to
the higher of (i) the pro rata share of the liquidation proceeds and (ii) the subscription price paid for the Series E preferred shares; then

iii.
 subject to the liquidation preferences above, to the holders of Series D preferred shares, in an amount equal
to the higher of (i) the pro rata share of the liquidation proceeds and (ii) the subscription price paid for the Series D preferred shares; then

iv.
 to all shareholders in proportion to the nominal value of their shares;

•

 the lack of an active public market for the Company’s securities;

•

 the Company’s stage of development and its business strategy, external market and economic conditions
affecting the industry in which it operates, and trends within that industry;

•

 the valuations of similarly situated companies and of competitors within the Company’s industry;

•

 the Company’s stage of development, and the likelihood of development and commercial success of the SOPHiA
platform and related offerings;

•

 the likelihood of achieving a liquidity event; and

•

 analysis of initial public offerings and the market performance of comparable companies in the Company’s
industry.

 Methods of Determining Historical Fair Value of Share Options

For convenience, the first part of the Staff’s comment is repeated below in italics, but with the per share values updated to reflect the Share Split:

 We note from page F-41 that the weighted average fair value of options granted in 2020 under the
2019 ISOP was $1.75 per share and from page F-39 that the weighted average exercise price of such options was $4.22 per share, which appears more consistent with the range of share prices of options granted in
2020 under this ISOP of $4.36-$4.87 per share (page F-40). Please explain the significant difference between the aforementioned weighted average fair value and weighted
average exercise price.

 The fair value of the options granted under the 2019 ISOP are calculated using the traditional Black-Scholes option pricing
model.

 In consultation with the independent third-party valuation specialists referred to above, the Company applies a Black-Scholes option pricing
model-based valuation method using assumptions and inputs that the Company believes are reasonable to arrive at an estimated fair value of the options for the purpose of determining share-based compensation expense. These inputs for determining the
fair value of options are set forth in the note 25, “Share-based compensation”, of the Financial Statements and include the following:

•

 The fair value of the underlying share at the grant date;

•

 The exercise price of the option;

•

 The expected life of the option;

•

 The expected volatility in the share price;

•

 The risk-free interest rate; and

3

 Jenn Do

 Brian Cascio

Division of Corporation Finance,

 Office of Life Sciences

U.S. Securities and Exchange

 Commission

•

 The dividend yield.

The fair value of the underlying share at the grant date: As there is no public market for the Company’s securities, the fair value of the
underlying share was determined using methods such as those explained in “Methods of Determining Historical Fair Value of Shares” below.

 The
exercise price of the option: The exercise price is set by the Company at grant date. As the purpose of share-based awards such as options is to motivate plan participants, the Company believes that it is customary for the exercise price to be
approximately equal to the estimated share price at grant date (i.e., the option is granted “at the money”). This means that the option has no “intrinsic value” at grant date but only “time value” that depends on the
future appreciation in value of the underlying share during the expected life of the option. Granting the option at the money aligns the Company’s interests with those of the plan participants, who are incentivized to contribute to the growth
of the Company’s share price. It is therefore to be expected that the range of share prices in 2020 (being $4.36-$4.87) does not differ significantly from the weighted-average exercise price (being
$4.22). Some differences could nevertheless arise between the range of share prices and the weighted-average exercise price as exercise prices were fixed at the date of grant while the final detailed estimation of share prices in accordance with
methods, approaches and assumptions consistent with AICPA guidelines was performed only in 2021.

 The expected life of the option: The expected
life of the option is the mean of (i) the shorter of (a) the vesting period, which is four years after grant for the 2019 ISOP and (b) the term to the Offering that was used in the most recent valuation of the ordinary shares and
(ii) the legal term of the option, which is ten years after grant. The longer the expected life, the greater the opportunity for the share price to appreciate and therefore the greater the option value. This approach resulted in a range of
expected life values for 2020 of between 5.67 and 6.43 years.

 The expected volatility in the share price: The expected volatility input for 2020
of between 39.8% and 43.6% was developed by analyzing the standard deviation of historical share prices of publicly traded companies with operations similar to those of the Company. The guideline companies were selected where possible to match or
approximate the term of the option and the nature of the Company’s operations.

 The risk-free interest rate: The risk-free rate for 2020 of
between -0.53% and -0.80% was based on the rate of Swiss government securities with the same term as the options.

The dividend yield: The dividend yield is assumed to be zero, as the Company has never paid dividends, is not yet profitable and does not intend to pay
dividends in the foreseeable future.

 Using these inputs, the Black-Scholes model produced a weighted-average fair value of options granted in 2020 of
$1.75, which the Company believes is reasonable in the context of the inputs explained above. As explained above, we would expect to see similarity between the weighted-average exercise price and the fair value of the underlying shares. However, as
the weighted-average fair value of options reflects the likelihood and extent of future growth in the fair value of an ordinary share within the expected life of the option in excess of the exercise price, we would not expect parity between, on the
one hand, the weighted-average fair value of options and, on the other hand, the weighted-average exercise price and the fair value of the underlying shares.

Methods of Determining Historical Fair Value of Shares

For convenience, the second part of the Staff’s comment is repeated below in italics:

Once you have an estimated offering price or range, please explain to us the reasons for any differences between the recent valuations of your
common stock leading up to the initial public offering and the estimated offering price.

4

 Jenn Do

 Brian Cascio

Division of Corporation Finance,

 Office of Life Sciences

U.S. Securities and Exchange

 Commission

 Methods Used to Value the Company’s Ordinary Shares

The Company’s share capital is composed of Series D, E and F preferred shares and ordinary shares. Each class of preferred shares includes economic rights
and preferences over previously issued classes of preferred shares, and all classes of preferred shares include economic rights and preferences, including liquidation preference, over ordinary shares. To estimate the fair value of the Company’s
ordinary shares for options granted in 2020 and in the first three months of 2021, the Company selected methods (i) to value the company, (ii) to allocate the company’s value to each share class and (iii) to consider the need for
a discount for lack of marketability (“DLOM”).

 Methods Used to Value the Company

A common approach for valuing a company is the backsolve method, which is a market approach. This method derives the implied equity value for the company from
a transaction involving the company’s own securities. In deriving this value, specific consideration is given to the rights and preferences of each class of equity. This method was used for options granted on

CORRESP
1
filename1.htm

CORRESP

 +1 212 450 4000

 davispolk.com

 Davis Polk & Wardwell LLP

450 Lexington Avenue

 New York, NY 10017

 July 2, 2021

Re:
 SOPHiA GENETICS SA

 Draft Registration Statement on Form F-1

 Submitted on May 24, 2021

 CIK No. 0001840706

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:

Ms. Irene Paik

Mr. Jason Drory

 Dear Ms. Paik and Mr. Drory:

On behalf of our client, SOPHiA GENETICS SA (the “Company”), this letter sets forth the Company’s responses to the comments provided by the
staff (the “Staff”) of the U.S. Securities and Exchange Commission relating to the Company’s Draft Registration Statement on Form F-1 submitted on May 24, 2021 (the “Draft Registration
Statement”) contained in the Staff’s letter dated June 22, 2021 (the “Comment Letter”). In response to the comments set forth in the Comment Letter, the Company has revised the Draft Registration Statement and is publicly
filing its Registration Statement on Form F-1 (the “Registration Statement”) together with this response letter. The Registration Statement also contains certain additional updates and revisions.

 For the convenience of the Staff, each comment from the Comment Letter is restated in italics prior to the response to such comment. All references to
page numbers and captions (other than those in the Staff’s comments) correspond to pages and captions in the Registration Statement.

 Draft
Registration Statement on Form F-1 submitted on May 24, 2021

 Prospectus Summary

Overview, page 1

1.
 We note your disclosure in your prospectus summary that you “estimate the total addressable market
opportunities in 2020 for [y]our current commercial clinical applications and for [y]our current biopharma applications were approximately $21 billion and $14 billion, respectively” and that you
“estimate that [y]our clinical and biopharma applications targeted a $35 billion global total addressable market opportunity in 2020, $14 billion of which was in the United States.” In addition, we
note your statement that you believe that your SOPHiA platform “is one of the most widely used decentralized analytics platform globally for clinical genomics” and had $28.4 million in revenue for the year ended
December 31, 2020. Please reconcile these statements by providing us the basis for your total addressable market and disclose any material assumptions and limitations associated with your estimate of the total addressable
market.

 Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages
138-140 of the Registration Statement to disclose the material assumptions and limitations associated with the Company’s estimate of the total addressable market. In addition, the Company is submitting, under separate cover, the basis for the
Company’s statements regarding its total addressable market.

 Ms. Irene Paik

 Mr. Jason Drory

Division of Corporation Finance

 U.S. Securities and Exchange

Commission

 Overview, page 1

2.
 We note that you highlight here that “[a]s of March 31, 2021, [you] served more than
750 hospital, laboratory and biopharma customers globally.” Please also disclose the number of recurring platform customers as of a recent date.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 2, 92 and 122 of the Registration
Statement.

 Overview, page 2

3.
 We note your disclosure on page 2 that you commercialize your SOPHiA platform and related solutions,
products and services as RUO and CE-IVD products. Please clarify here that in the United States, SOPHiA products are labeled and sold for research use only, and not for the diagnosis or treatment of disease.
In addition, with reference to your disclosure on pages 154 and 156 regarding the RUO and CE-IVD designations, please briefly explain here the limitations placed on RUO products and the process by which your
in vitro devices received a CE mark.

 Response: The Company respectfully acknowledges the Staff’s comment and has
revised the disclosure on pages 2, 92 and 122-123 of the Registration Statement.

 Market and Industry Data,
page 83

4.
 We note your statements regarding market data used in the prospectus, including that the sources of the
information do not guarantee the accuracy or completeness of the information and that investors are cautioned “not to give undue weight” to projections, assumptions and estimates. Please revise these statements to eliminate any implication
that investors are not entitled to rely on the information included in your registration statement.

 Response: The Company
respectfully acknowledges the Staff’s comment and has revised the disclosure on page 84 of the Registration Statement.

 Use of Proceeds, page 84

5.
 We note your disclosure on page 104 that you remain obligated to pay your lender, TriplePoint, a fee upon
the completion of this offering. To the extent the offering proceeds will be used to pay this obligation, please disclose the fee owed to TriplePoint here.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 85 of the Registration Statement.

Management’s Discussion and Analysis of Financial Conditions and Results of Operations

Results of Operations, page 101

6.
 We note the manufacturing, marketing and supply agreements (collaboration agreements) discussed on pages 145-147. If these had a material impact on your results of operations please revise to quantify the impact each period.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 104 and 107 of the Registration
Statement to quantify the impact of the Company’s manufacturing and supply agreement with Integrated DNA Technologies, Inc. and the OEM supply agreement with Qiagen GmbH on the Company’s results of operations (i.e., the Company’s cost
of revenue) for each period presented. The Company respectfully informs the Staff that the remaining manufacturing, marketing and supply agreements (collaboration agreements) discussed in the Registration Statement did not have a material impact on
the Company’s results of operations for periods presented.

July 2, 2021

2

 Ms. Irene Paik

 Mr. Jason Drory

Division of Corporation Finance

 U.S. Securities and Exchange

Commission

 Cost of Revenue, page 102

7.
 Please revise to quantify each of the factors related to the increase in costs of revenue for 2020,
including the write-off associated with the loss of the large customer.

 Response:
The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 104 of the Registration Statement.

 Research
and Development Costs, page 102

8.
 We note you attribute the increase in research and development costs in 2020 to several factors, including
the development of new products and applications, expansion of your SOPHiA platform’s multimodal capabilities and EHR integration. Please revise to quantify and discuss each of the reasons and contributing factors for the increase in research
and development costs.

 Response: The Company respectfully acknowledges the Staff’s comment and has revised the
disclosure on pages 104 and 107 of the Registration Statement.

 Revenue, page 102

9.
 Please revise to separately discuss and quantify each of the factors contributing to the increase in SOPHiA
platform revenue, including the amount attributable to the access model mix shift from dry lab to bundle access, growth in Alamut license revenue and ramp-up in your biopharma services revenue.

 Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 103-104 and 106 of the Registration Statement.

 Business

Our SOPHiA Platform Architecture, page 121

10.
 Please clarify the meaning of scientific or technical terms the first time they are used in order to ensure
that lay readers will understand the disclosure. For example, please briefly explain what you mean by an “Extract Transform Load engine.”

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 127 of the Registration Statement. In
addition, the Company has revised the disclosure throughout the Registration Statement to ensure that lay readers will understand the disclosure.

Biopharma Applications, page 128

11.
 We note your disclosure that you began commercializing biopharma applications in 2019. Please provide
additional disclosure here describing how your biopharma applications are being accepted in the biopharma market, including quantifying how many customers have used your biopharma applications.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 135 of the Registration Statement.

High Visibility and Predictability into Our Business, page 138

12.
 We note your disclosure that, “[o]nce onboarded onto [y]our SOPHiA platform, [y]our customers tend to
steadily increase their use of [y]our SOPHiA platform.” However, we note your platform analysis volume by cohort excludes volume contributions from your integrated access customers

July 2, 2021

3

 Ms. Irene Paik

 Mr. Jason Drory

Division of Corporation Finance

 U.S. Securities and Exchange

Commission

due to the fact they are a “a small percentage of [y]our overall volume and utilize [y]our platform in an ad hoc manner.” Please revise your disclosure to discuss how the integrated
access model fits into your “land and expand” growth strategy or otherwise advise.

 Response: The Company respectfully
advises the Staff that the Company’s integrated access customers contribute to a small percentage of the Company’s overall volume and utilize the Company’s platform in an ad hoc manner compared to the Company’s dry lab and bundle
access customers who typically do so in a recurring fashion. Consequently, the Company does not consider its integrated access model a material element of its “land and expand” commercial strategy. The Company further respectfully advises
the Staff that it has revised the disclosure on pages 145-146 of the Registration Statement accordingly.

Platform Analysis Volume by Cohort - Steady “Land and Expand” Growth, page 138

13.
 We note your graphic on page 138 depicting annual platform analysis volume of various customer cohorts over
time. Please revise the graphic to quantify the annual platform analysis volume for each cohort for each year shown.

 Response:
The Company respectfully acknowledges the Staff’s comment and has revised the graphic on page 145 of the Registration Statement.

Biopharma Case Study, page 141

14.
 We note your disclosure regarding your support of your customer’s
in-depth re-analysis of its proprietary clinical trial data using a multimodal approach, including your customer’s objective. Please add additional disclosure here
discussing any results or otherwise advise if the project is still ongoing.

 Response: The Company respectfully acknowledges
the Staff’s comment and has revised the disclosure on page 148 of the Registration Statement.

 Patents, page 143

15.
 With respect to material patents, please describe the specific products, product groups and technologies to
which such patents relate (e.g. SOPHiA DDM, Alamut, etc.), the scope of your most significant patents, the jurisdictions in which they were issued, and when they will expire. If you do not believe you hold any material patents, please revise your
disclosure accordingly.

 Response: The Company respectfully acknowledges the Staff’s comment and has revised the
disclosure on page 150 of the Registration Statement.

 Normandie Valorisation—Exclusive License Agreements, page 144

16.
 Please revise your disclosure here to clarify the product(s) for which you are required to pay the per
analysis fee under the license agreement.

 Response: The Company respectfully acknowledges the Staff’s comment and has
revised the disclosure on page 152 of the Registration Statement.

 Medical Device Regulatory Framework, page 150

17.
 Given your global footprint as referenced on page 140, please provide a brief overview of the regulatory
framework for any additional material jurisdictions in which you distribute your products and describe any limitations on your ability to commercialize your products in that jurisdiction.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages
164-165 of the Registration Statement.

July 2, 2021

4

 Ms. Irene Paik

 Mr. Jason Drory

Division of Corporation Finance

 U.S. Securities and Exchange

Commission

 Principal Shareholders, page 177

18.
 Please revise footnote 2 to identify the natural persons who are the beneficial owners of the shares held by
Generation IM Sustainable Solutions Fund III, L.P.

 Response: The Company respectfully informs the Staff that Generation IM
Sustainable Solutions Fund III, L.P. is the record holder of the ordinary shares. The general partner of Generation IM Sustainable Solutions Fund III L.P. is Generation IM Sustainable Solutions III, GP Ltd, which is a wholly owned subsidiary of
Generation Investment Management LLP, which is the investment manager of Generation IM Sustainable Solutions Fund III, L.P. Generation Investment Management LLP is controlled by a management committee that comprises three or more individuals.
Pursuant to the so-called “rule of three,” if voting or investment decisions with respect to issuer securities require a vote of a majority of three or more persons, none of them will be deemed the
beneficial owner of those securities for purposes of Section 13(d). See Southland Corp. (July 8, 1987). Because the management committee of Generation Investment Management LLP has three or more individuals, none of which exercises investment
or voting control over the Company’s securities (except with respect to the shares in which he or she directly holds a pecuniary interest), none of them will be deemed the beneficial owner of those securities for purposes of Section 13(d).
As such, no natural persons are required to be named in the Registration Statement.

 The Company further informs the Staff that Balderton Capital VI,
S.L.P. is record holder of the ordinary shares. The general partner of Balderton Capital VI, S.L.P. is Balderton Capital General Partner VI, S.a.r.l. Balderton Capital General Partner VI, S.a.r.l. is controlled by an executive committee that
comprises three or more individuals. Because the executive committee of Balderton Capital General Partner VI, S.a.r.l. has three or more individuals, none of which exercises investment or voting control over the Company’s securities
(except with respect to the shares in which he or she directly holds a pecuniary interest), none of them will be deemed the beneficial owner of those securities for purposes of Section 13(d). As such, no natural persons are required to be named
in the Registration Statement. Consequently, the Company has revised the disclosure on page 188 of the Registration Statement accordingly.

 Notes to
the Consolidated Financial Statements

 25. Share-based Compensation, page F-38

19.
 We note from page F-41 that the weighted average fair value of
options granted in 2020 under the 2019 ISOP was $34.97 per share and from page F-39 that the weighted average exercise price of such options was $84.48 per share, which appears more consistent with the range
of share prices of options granted in 2020 under this ISOP of $87.29-$97.31 per share (page F-40). Please explain the significant difference between the aforementioned
weighted average fair value and weighted average exercise price. Once you have an estimated offering price or range, please explain to us the reasons for any differences between the recent valuations of your common stock leading up to the initial
public o

United States securities and exchange commission logo
June 22, 2021
Jurgi Camblong, Ph.D., M.B.A.
Chief Executive Officer
SOPHiA GENETICS SA
Rue du Centre 172
CH-1025 Saint-Sulpice
Switzerland
Re:SOPHiA GENETICS SA
Draft Registrant Statement on Form F-1
Submitted May 24, 2021
CIK No. 0001840706
Dear Dr. Camblong:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registrant Statement on Form F-1 submitted May 24, 2021
Prospectus Summary
Overview, page 1
1.We note your disclosure in your prospectus summary that you "estimate the total
addressable market opportunities in 2020 for [y]our current commercial clinical
applications and for [y]our current biopharma applications were approximately $21 billion
and $14 billion, respectively" and that you "estimate that [y]our clinical and biopharma
applications targeted a $35 billion global total addressable market opportunity in 2020,
$14 billion of which was in the United States." In addition, we note your statement that
you believe that your SOPHiA platform "is one of the most widely used decentralized

 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
 Comapany NameSOPHiA GENETICS SA
 June 22, 2021 Page 2
 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
SOPHiA GENETICS SA
June 22, 2021
Page 2
analytics platform globally for clinical genomics" and had $28.4 million in revenue for the
year ended December 31, 2020. Please reconcile these statements by providing us the
basis for your total addressable market and disclose any material assumptions and
limitations associated with your estimate of the total addressable market.
2.We note that you highlight here that "[a]s of March 31, 2021, [you] served more than 750
hospital, laboratory and biopharma customers globally."  Please also disclose the number
of recurring platform customers as of a recent date.
3.We note your disclosure on page 2 that you commercialize your SOPHiA platform and
related solutions, products and services as RUO and CE-IVD products.  Please clarify here
that in the United States, SOPHiA products are labeled and sold for research use only, and
not for the diagnosis or treatment of disease.  In addition, with reference to your disclosure
on pages 154 and 156 regarding the RUO and CE-IVD designations, please briefly
explain here the limitations placed on RUO products and the process by which your in
vitro devices received a CE mark.
Market and Industry Data, page 83
4.We note your statements regarding market data used in the prospectus, including that the
sources of the information do not guarantee the accuracy or completeness of the
information and that investors are cautioned "not to give undue weight" to projections,
assumptions and estimates. Please revise these statements to eliminate any implication
that investors are not entitled to rely on the information included in your registration
statement.
Use of Proceeds, page 84
5.We note your disclosure on page 104 that you remain obligated to pay your lender,
TriplePoint, a fee upon the completion of this offering.  To the extent the offering
proceeds will be used to pay this obligation, please disclose the fee owed to TriplePoint
here.
Management's Discussion and Analysis of Financial Conditions and Results of Operations
Results of Operations, page 101
6.We note the manufacturing, marketing and supply agreements (collaboration agreements)
discussed on pages 145-147.  If these had a material impact on your results of operations
please revise to quantify the impact each period.
Cost of Revenue, page 102
7.Please revise to quantify each of the factors related to the increase in costs of revenue for
2020, including the write-off associated with the loss of the large customer.

 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
 Comapany NameSOPHiA GENETICS SA
 June 22, 2021 Page 3
 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
SOPHiA GENETICS SA
June 22, 2021
Page 3
Research and Development Costs, page 102
8.We note you attribute the increase in research and development costs in 2020 to several
factors, including the development of new products and applications, expansion of your
SOPHiA platform’s multimodal capabilities and EHR integration.  Please revise to
quantify and discuss each of the reasons and contributing factors for the increase in
research and development costs.
Revenue, page 102
9.Please revise to separately discuss and quantify each of the factors contributing to the
increase in SOPHiA platform revenue, including the amount attributable to the access
model mix shift from dry lab to bundle access, growth in Alamut license revenue and
ramp-up in your biopharma services revenue.
Business
Our SOPHiA Platform Architecture, page 121
10.Please clarify the meaning of scientific or technical terms the first time they are used in
order to ensure that lay readers will understand the disclosure. For example, please
briefly explain what you mean by an "Extract Transform Load engine."
Biopharma Applications, page 128
11.We note your disclosure that you began commercializing biopharma applications in 2019.
Please provide additional disclosure here describing how your biopharma applications are
being accepted in the biopharma market, including quantifying how many customers have
used your biopharma applications.
High Visibility and Predictability into Our Business, page 138
12.We note your disclosure that, "[o]nce onboarded onto [y]our SOPHiA platform, [y]our
customers tend to steadily increase their use of [y]our SOPHiA platform." However, we
note your platform analysis volume by cohort excludes volume contributions from your
integrated access customers due to the fact they are a "a small percentage of [y]our overall
volume and utilize [y]our platform in an ad hoc manner." Please revise your disclosure to
discuss how the integrated access model fits into your "land and expand" growth strategy
or otherwise advise.
Platform Analysis Volume by Cohort - Steady "Land and Expand" Growth, page 138
13.We note your graphic on page 138 depicting annual platform analysis volume of various
customer cohorts over time. Please revise the graphic to quantify the annual platform
analysis volume for each cohort for each year shown.

 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
 Comapany NameSOPHiA GENETICS SA
 June 22, 2021 Page 4
 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
SOPHiA GENETICS SA
June 22, 2021
Page 4
Biopharma Case Study, page 141
14.We note your disclosure regarding your support of your customer's in-depth re-analysis of
its proprietary clinical trial data using a multimodal approach, including your customer's
objective. Please add additional disclosure here discussing any results or otherwise advise
if the project is still ongoing.
Patents, page 143
15.With respect to material patents, please describe the specific products, product groups and
technologies to which such patents relate (e.g. SOPHiA DDM, Alamut, etc.), the scope of
your most significant patents, the jurisdictions in which they were issued, and when they
will expire. If you do not believe you hold any material patents, please revise your
disclosure accordingly.
Normandie Valorisation-Exclusive License Agreements, page 144
16.Please revise your disclosure here to clarify the product(s) for which you are required to
pay the per analysis fee under the license agreement.
Medical Device Regulatory Framework, page 150
17.Given your global footprint as referenced on page 140, please provide a brief overview of
the regulatory framework for any additional material jurisdictions in which you distribute
your products and describe any limitations on your ability to commercialize your products
in that jurisdiction.
Principal Shareholders, page 177
18.Please revise footnote 2 to identify the natural persons who are the beneficial owners of
the shares held by Generation IM Sustainable Solutions Fund III, L.P.
Notes to the Consolidated Financial Statements
25. Share-based Compensation, page F-38
19.We note from page F-41 that the weighted average fair value of options granted in 2020
under the 2019 ISOP was $34.97 per share and from page F-39 that the weighted average
exercise price of such options was $84.48 per share, which appears more consistent with
the range of share prices of options granted in 2020 under this ISOP of $87.29-$97.31 per
share (page F-40). Please explain the significant difference between the aforementioned
weighted average fair value and weighted average exercise price. Once you have an
estimated offering price or range, please explain to us the reasons for any differences
between the recent valuations of your common stock leading up to the initial public
offering and the estimated offering price.

 FirstName LastNameJurgi Camblong, Ph.D., M.B.A.
 Comapany NameSOPHiA GENETICS SA
 June 22, 2021 Page 5
 FirstName LastName
Jurgi Camblong, Ph.D., M.B.A.
SOPHiA GENETICS SA
June 22, 2021
Page 5
General
20.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.
            You may contact Jenn Do at 202-551-3743 or Brian Cascio at 202-551-3676 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Jason Drory at 202-551-8342 or Irene Paik at 202-551-3676 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Yasin Keshvargar, Esq.