SecProbe.io

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 CORRESP

 Alpha Teknova, Inc.
 2451 Bert Drive Hollister, CA
95023 July 14, 2025 VIA EDGAR
 United States Securities and Exchange Commission Division of
Corporation Finance Office of Life Sciences 100 F Street,
N.E. Washington, D.C. 20549-0406 Attention: Jason Drory

 Re:
 Alpha Teknova, Inc.

  
 Registration Statement on Form S-3

  
 Filed July 10, 2025

  
 Registration No. 333-288613
 Ladies and Gentlemen: Pursuant to Rule 461
under the Securities Act of 1933, as amended, Alpha Teknova, Inc. (the “ Company ”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-3
(File No. 333-288613) of the Company, filed with the Securities and Exchange Commission on July 10, 2025 (the “ Registration Statement ”), be accelerated so that the
Registration Statement shall become effective at 4:00 p.m., Eastern Time, on July 16, 2025 or as soon as possible thereafter. As of the date hereof, there is no managing or principal underwriter for any of the Company’s securities that may
be offered pursuant to the Registration Statement. Future managing or principal underwriters, if any, will be identified in a prospectus supplement to the Registration Statement at the time of offering.
 The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange
Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement. It would be
appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Elizabeth A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1895 or by email at
elizabethrazzano@paulhastings.com. The Company hereby authorizes Ms. Elizabeth A. Razzano of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

 Sincerely,

 ALPHA TEKNOVA, INC.

  By:

 /s/ Matthew Lowell

 Matthew Lowell

 Chief Financial Officer

 cc:
 Elizabeth A. Razzano, Esq. (Paul Hastings LLP)

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 14, 2025

Stephen Gunstream
President and Chief Executive Officer
Alpha Teknova, Inc.
2451 Bert Drive
Hollister, CA 95023

 Re: Alpha Teknova, Inc.
 Registration Statement on Form S-3
 Filed July 10, 2025
 File No. 333-288613
Dear Stephen Gunstream:

 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 Jason Drory at 202-551-8342 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
cc: Jeff Hartlin
</TEXT>
</DOCUMENT>

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CORRESP

 Alpha Teknova, Inc.

2451 Bert Dr.

 Hollister, CA 95023

 August 27, 2024

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Life Sciences

 100 F Street,
N.E.

 Washington, D.C. 20549-0406

 Attention: Jimmy McNamara

Re:
 Alpha Teknova, Inc.

Registration Statement on Form S-1

Registration No. 333-281765

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Alpha Teknova, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-1
(File No. 333-281765) of the Company, filed with the Securities and Exchange Commission (the “Commission”) on August 23, 2024 (the “Registration
Statement”), be accelerated so that such Registration Statement shall become effective at 5:00 p.m., Eastern Time, on August 29, 2024 or as soon as possible thereafter. There are no underwriters for this proposed offering, which is
an offering of the Company’s common stock by selling stockholders.

 The Company hereby confirms that it is aware of its
responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement.

It would be appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Elizabeth
A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1895 or by email at elizabethrazzano@paulhastings.com. The Company hereby authorizes Ms. Elizabeth A. Razzano of Paul Hastings LLP to orally
modify or withdraw this request for acceleration.

Sincerely,

ALPHA TEKNOVA, INC.

By:

/s/ Stephen Gunstream

Stephen Gunstream

President and Chief Executive Officer

cc:
 Elizabeth A. Razzano, Esq. (Paul Hastings LLP)

August 27, 2024
Stephen Gunstream
Chief Executive Officer
Alpha Teknova, Inc.
2451 Bert Dr.
Hollister, CA 95023
Re:Alpha Teknova, Inc.
Registration Statement on Form S-1
Filed August 23, 2024
File No. 333-281765
Dear Stephen Gunstream:
            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 Jimmy McNamara at 202-551-7349 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:Elizabeth Razzano

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CORRESP

 Alpha Teknova, Inc.

2451 Bert Dr.

 Hollister, CA 95023

 November 3, 2023

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Life Sciences

 100 F Street,
N.E.

 Washington, D.C. 20549-0406

 Attention: Cindy Polynice

Re:
 Alpha Teknova, Inc.

Registration Statement on Form S-1

Registration No. 333-275168

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Alpha Teknova, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-1
(File No. 333-275168) of the Company, filed with the Securities and Exchange Commission (the “Commission”) on October 25, 2023 (the “Registration
Statement”), be accelerated so that such Registration Statement shall become effective at 5:00 p.m., Eastern Time, on November 7, 2023 or as soon as possible thereafter. There are no underwriters for this proposed offering, which
is an offering of the Company’s common stock by selling stockholders.

 The Company hereby confirms that it is aware of its
responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement.

It would be appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Elizabeth
A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1895 or by email at elizabethrazzano@paulhastings.com. The Company hereby authorizes Ms. Elizabeth A. Razzano of Paul Hastings LLP to orally
modify or withdraw this request for acceleration.

Sincerely,

ALPHA TEKNOVA, INC.

By:

 /s/ Matthew Lowell

Matthew Lowell

Chief Financial Officer

cc:
 Elizabeth A. Razzano, Esq. (Paul Hastings LLP)

United States securities and exchange commission logo
November 2, 2023
Stephen Gunstream
President and Chief Executive Officer
Alpha Teknova, Inc.
2451 Bert Dr.
Hollister, CA 95023
Re:Alpha Teknova, Inc.
Registration Statement on Form S-1
Filed October 25, 2023
File No. 333-275168
Dear Stephen Gunstream:
            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 Cindy Polynice at 202-551-8707 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Elizabeth Razzano, Esq.

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CORRESP

 Alpha Teknova, Inc.

2451 Bert Drive

 Hollister, CA
95023

 July 8, 2022

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Office of Life Sciences

 100 F Street,
N.E.

 Washington, D.C. 20549-0406

 Attention: Jordan Nimitz

Re:
 Alpha Teknova, Inc.

 Registration Statement on Form S-3

 Registration No. 333-265987

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Alpha Teknova, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-3
(File No. 333-265987) of the Company, filed with the Securities and Exchange Commission on July 1, 2022 (the “Registration Statement”), be accelerated so that the Registration
Statement shall become effective at 4:30 p.m., Eastern Time, on July 12, 2022 or as soon as possible thereafter. As of the date hereof, there is no managing or principal underwriter for any of the Company’s securities that may be offered
pursuant to the Registration Statement. Future managing or principal underwriters, if any, will be identified in a prospectus supplement to the Registration Statement at the time of offering.

The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange
Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement.

 It would be
appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Elizabeth A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1895 or by email at
elizabethrazzano@paulhastings.com. The Company hereby authorizes Ms. Elizabeth A. Razzano of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

 Sincerely,

 ALPHA TEKNOVA, INC.

 By:

 /s/ Matthew Lowell

 Matthew Lowell

 Chief Financial Officer

 cc:    Elizabeth A. Razzano, Esq. (Paul Hastings LLP)

United States securities and exchange commission logo
July 8, 2022
Stephen Gunstream
President and Chief Executive Officer
Alpha Teknova, Inc.
2451 Bert Drive
Hollister, CA 95023
Re:Alpha Teknova, Inc.
Registration Statement on Form S-3
Filed July 1, 2022
File No. 333-265987
Dear Mr. Gunstream:
            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

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Underwriter Acceleration Request

 June 23, 2021

VIA EDGAR

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Alpha Teknova, Inc.

 Registration Statement on
Form S-1 (File No. 333-256795)

Attn:
 Ms. Julie Sherman

 Ms. Mary Mast

 Mr. Alan Campbell

 Ms. Laura Crotty

Ladies and Gentlemen:

 Pursuant to Rule 460 under the
Securities Act of 1933, as amended, (the “Act”), we wish to advise you that between June 21, 2021 and the date hereof, approximately 2,339 copies of the Preliminary Prospectus, dated June 21, 2021, were distributed
to prospective underwriters, institutional investors, prospective dealers, individuals and others.

 We have been informed by the participating
underwriters 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.

In accordance with Rule 461 under the Act, 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 June 24, 2021, or as soon thereafter as practicable, or at such other time as the registrant or its counsel may request by telephone call to the Staff of the Division of
Corporation Finance of the Securities and Exchange Commission.

 [Signature page follows.]

Very truly yours,

COWEN AND COMPANY, LLC

WILLIAM BLAIR & COMPANY, L.L.C.

Acting on their own behalf

and as Representatives of several

Underwriters listed on Schedule A to the
Underwriting Agreement.

By:

COWEN AND COMPANY, LLC

By:

 /s/ Jay Coleman

Name: Jay Coleman

Title:   Managing Director

By:

WILLIAM BLAIR & COMPANY, L.L.C.

By:

 /s/ Rakhee Bhagat

Name: Rakhee Bhagat

Title:   Partner, Managing Director

CORRESP
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Company Acceleration Request

 Alpha Teknova, Inc.

2290 Bert Dr.

 Hollister, CA 95023

June 23, 2021

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 Attention: Office of Life Sciences

 100
F Street, N.E.

 Washington, D.C. 20549-0406

Re:
 Alpha Teknova, Inc.

 Registration Statement on Form S-1, as amended

 Registration No. 333-256795

Ladies and Gentlemen:

 Pursuant to
Rule 461 under the Securities Act of 1933, as amended, Alpha Teknova, Inc. (the “Company”) hereby respectfully requests that the effectiveness of the Registration Statement on
Form S-1 (File No. 333-256795) of the Company, filed with the Securities and Exchange Commission (the “Commission”) on June 21,
2021, as amended (the “Registration Statement”), be accelerated so that such Registration Statement shall become effective at 4:00 p.m., Eastern Time, on June 24, 2021 or as soon as possible thereafter.

The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange
Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement.

 It would be
appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Jeffrey T. Hartlin of Paul Hastings LLP, by telephone at (650) 320-1804 or by email at
jeffhartlin@paulhastings.com, and Elizabeth A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1804 or by email at elizabethrazzano@paulhastings.com. The Company hereby authorizes Mr. Hartlin or
Ms. Razzano of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

Sincerely,

ALPHA TEKNOVA, INC.

By:

 /s/ Stephen Gunstream

Name:

Stephen Gunstream

Title:

President and Chief Executive Officer

cc:
 Jeffrey T. Hartlin, Esq. (Paul Hastings LLP)

 Elizabeth A. Razzano, Esq. (Paul Hastings LLP)

CORRESP
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CORRESP

 June 21, 2021

Ms. Julie Sherman

 Ms. Mary Mast

Mr. Alan Campbell

 Ms. Laura Crotty

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Life Sciences

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Alpha Teknova, Inc.

 Registration Statement on Form S-1

 CIK No. 0001850902

Ladies and Gentlemen:

 This letter responds to the comments of
the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Mr. Stephen Gunstream, President and Chief Executive Officer of Alpha Teknova, Inc., a Delaware corporation
(“Teknova” or the “Company”), in the letter dated May 4, 2021 (the “Staff Letter”) regarding the Company’s Draft Registration Statement on Form S-1 confidentially submitted to the Commission on April 5, 2021 and subsequently filed with the Commission on June 4, 2021 (File No. 333-256795) (the
“June 4 Registration Statement”). The Company is concurrently filing with the Commission an amendment to the June 4 Registration Statement on Form
S-1 (the “Registration Statement”). In addition, the Company is sending a copy of this letter and the Registration Statement in typeset format, including a version that is marked to
show changes to the June 4 Registration Statement, to the Staff.

 CONFIDENTIAL TREATMENT REQUESTED BY ALPHA TEKNOVA, INC.

Because of the commercially sensitive nature of information contained herein, this submission is accompanied by the Company’s request for confidential
treatment for selected portions of this letter. The Company has filed a separate letter with the Office of Freedom of Information and Privacy Act Operations in connection with the confidential treatment request, pursuant to Rule 83 of the
Commission’s Rules on Information and Requests, 17 C.F.R. § 200.83. For the Staff’s reference, we have enclosed a copy of the Company’s letter to the Office of Freedom of Information and Privacy Act Operations, as well as a copy
of this correspondence, marked to show the portions redacted from the version filed via EDGAR and for which the Company is requesting confidential treatment.

The numbering of the paragraphs below corresponds to the numbering of the comment in the letter from the Staff. For the Staff’s convenience, the Company
has incorporated your comment into this response letter (in bold italics). Page references in the text of this response letter correspond to the page numbers in the Amended Draft Registration Statement. Capitalized terms used in this
letter but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration Statement.

 [*] Certain confidential
information in this letter, marked by brackets, has been omitted and filed separately with the SEC pursuant to 17 C.F.R. §200.83.

 June 21, 2021

  Page
 2

 Management’s Discussion and Analysis of Financial Condition and Results of Operations Stock-Based
Compensation, page 87

 9. Once you have an estimated offering price or range, please explain to us how you determined the fair value of the
common stock underlying your equity issuances and the reasons for any differences between the recent valuations of your common stock leading up to the IPO and the estimated offering price. This information will help facilitate our review of your
accounting for equity issuances including stock compensation and beneficial conversion features. Please discuss with the staff how to submit your response.

The Company respectfully submits the below additional information to assist the Staff in its review of the Company’s position with respect to its
determination of the fair value of its common stock underlying its outstanding equity issuances and the reasons for the differences between the recent valuation of its common stock and the estimated offering price for its initial public offering
(“IPO”).

 Overview

 As
discussed below, the Company utilized third-party valuations to estimate the fair value of the Company’s common stock, $0.00001 par value per share (which is referred to herein and in the Registration Statement as the “common
stock”) underlying its equity issuances consistent with the methods and guidance in the American Institute of Certified Public Accountants (“AICPA”) Audit and Accounting Practice Aid entitled Valuation of
Privately-Held-Company Equity Securities Issued as Compensation. During the financial periods presented in the Registration Statement, the first material option grant occurred in August 2020, after which time the Company utilized the then-most
current fair value estimate of the underlying the common stock to record stock-based compensation expense in its financial statements.

 The fair
value of the common stock has increased significantly in the last year, for both quantitative and qualitative reasons. A significant factor was the decision of the Company’s board of directors (the “Board”) in
early November 2020 to pursue an IPO of the common stock. The introduction of a public market valuation weighting in the Company’s December 2020 valuation had a significant impact, which became more pronounced in the March 2021 valuation as the
public equity market remained extraordinarily strong. In addition, the profound success of the COVID-19 vaccines had the effect of validating cell and gene therapy as effective platforms, helping to create a
supportive backdrop for an investment in the Company. During “testing-the-waters” meetings in May 2021, many potential investors expressed confidence in the
Company’s commercial and investment strategies, leading to a further increase in value reflected in the Price Range (as defined below).

 IPO Price
Range

 The Company advises the Staff that the underwriters in the IPO have communicated to the Company that they expect the price range for the common
stock to be between $14.00 and $16.00 per share (the “Price Range”), which takes into account a 1.8746-for-1 forward split of the common stock,
which was effected on June 17, 2021 (“Forward Stock Split”).

 As is typical in initial public offerings, the Price Range was
not derived using a formal determination of fair value but was derived primarily through discussions among the Company’s Board members, its senior management and representatives of the underwriters. The Price Range was based on a number of
factors, including prospects for the cell and gene therapy markets, the general condition of the securities markets and the valuations of recently completed

[*] Certain confidential information in this letter, marked by brackets, has been omitted and filed separately with the SEC pursuant to 17 C.F.R.
§200.83.

 June 21, 2021

  Page
 3

public offerings (including aftermarket performance and the respective stages of development of those issuers as compared to the Company), and significant positive feedback provided by potential
investors during the “testing-the-waters” meetings.

 Common
Stock Fair Value and Compensation Expense

 As stated in the Registration Statement, the Company has granted stock-based awards, consisting of common
stock options, to certain employees, directors and consultants.

 The Company measures stock-based awards granted to employees, directors, and consultants
based on their estimated fair value on the date of grant and recognizes compensation expense for those awards over the vesting period of the respective award. The Registration Statement describes the Company’s use of the Black-Scholes
option-pricing model (“Black-Scholes”) for the purpose of calculating the estimated grant date fair value of the stock options. The Company’s Board, with input from management, and contemporaneous third-party valuations
determines the estimated fair value per share of the common stock.

 The following table summarizes all stock options granted by the Company since
March 1, 2020, both the initial pre-Forward Stock Split values and the values after giving effect to the Forward Stock Split:

 Grant Date

 Total Shares Granted

Exercise Price per Share

Common Stock Fair Value
per Share
at Grant
Date used in the
Black Scholes model

 August 31, 2020

 1,530,704 post-split

816,551 pre-split

 $

$

 0.8368 post-split

1.5686 pre-split

$
 $

 [***]

[***]

 post-split

pre-split

 December 23, 2020

 309,309 post-split

165,000 pre-split

 $

$

 1.8458 post-split

3.4600 pre-split

$
 $

 [***]

[***]

 post-split

pre-split

 December 28, 2020

 84,357 post-split

40,000 pre-split

 $

$

 1.8458 post-split

3.4600 pre-split

$
 $

 [***]

[***]

 post-split

pre-split

 March 30, 2021

 196,833 post-split

105,000 pre-split

 $

$

 5.4412 post-split

10.2000 pre-split

$
 $

 [***]

[***]

 post-split

pre-split

 These estimated fair values per share of common stock were determined after considering valuation reports from an independent
third-party valuation specialist that incorporated objective and subjective factors as appropriate, including the Company’s stage of development, the Company’s cash burn and cash balances, management’s forecasts, the value of public
companies with similar profiles to the Company, the likelihood of achieving a liquidity event, and the other factors described below. As seen in the table above, for each grant the Company utilized a fair value above the exercise price to record
compensation expense in its financial statements. Set forth below is a discussion of each valuation and equity grant since March 1, 2020, along with a comparison of the estimated fair value of the common stock to the Price Range.

The Company did not make any material option grants during the 2019 Successor Period or the 2020 Successor Period (such periods being defined in the
Registration Statement) before August 31, 2020. Prior to such date, the Company obtained contemporaneous valuations throughout the historical periods (as well as periods prior to those presented in the Registration Statement) and used the fair
value of the underlying common stock within these valuation periods to determine the exercise price of options granted. There were instances in which the exercise price of the options granted

 [*] Certain confidential information in this letter, marked by brackets, has been
omitted and filed separately with the SEC pursuant to 17 C.F.R. §200.83.

 June 21, 2021

  Page
 4

was below the subsequently determined fair value of the underlying common stock. In all such instances, the fair value of the underlying common stock was used as an input in the Company’s
Black Scholes model to determine share-based compensation expense as shown in the table above.

 While this letter focuses on the common stock fair value
established for the equity awards granted since March 1, 2020, the Company also thought it important to provide some background on options granted from January 1, 2019 to March 1, 2020. The only options granted during that period were
151,863 (284,682 post-split) options granted to one individual on January 10, 2019, at an exercise price of $0.85 ($0.4534 post-split), which was below fair value and such fair value has been reflected in the Company’s estimate of future
expense to be recorded when the performance feature is probable. These options granted were performance based and were concluded not to be probable at every accounting period since the grant date through the date of this letter. Following this
grant, on August 31, 2019, the Company obtained a 409A valuation with a determined fair value of $[***] ($[***] post-split); however, this valuation was not used in the accounting for share based compensation expense, but rather was only used
to determine the exercise price of options granted on August 31, 2020. As shown in the table above, the fair value of the underlying common stock used in the Black Scholes model when calculating stock-based compensation expense for the
August 31, 2020 grant was $[***] ($[***] post-split).

 Determining Fair Value of Common Stock prior to the IPO

As there has been no public market for the common stock to date, the estimated fair value of common stock for purposes of granting equity awards has been
determined by the Board, as of the date of each option grant. The Board considered the Company’s most recent third-party valuations of its common stock when making such determinations.

The third-party valuations of common stock that the Board considered in making its determinations were prepared in accordance with guidance from the AICPA
Audit and Accounting Practice Aid entitled Valuation of Privately-Held-Company Equity Securities Issued as Compensation. The most recent valuation report prepared was as of March 31, 2021.

A summary of the common stock valuations is as follows:

 Valuation Date

(As of Date)

Fair Value per
Share of
Common Stock

 September 30, 2020

$[***]

post-split

$[***]

pre-split

 December 31, 2020

$[***]

post-split

$[***]

pre-split

 March 31, 2021

$[***]

post-split

$[***]

pre-split

 September 30, 2020 Valuation

An option pricing methodology (“OPM”) was utilized in the September 30, 2020 valuation to arrive at the fair value estimate of the
underlying common stock. The OPM allocation was utilized because the Company had no definitive expectations of a liquidity event as of the effective date of the valuation. The probability-weighted expected return method
(“PWERM”) was not appropriate for the Company because the Company lacked future possible outcomes

[*] Certain confidential information in this letter, marked by brackets, has been omitted and filed separately with the SEC pursuant to 17 C.F.R.
§200.83.

 June 21, 2021

  Page
 5

with enough certainty to explicitly model, as is necessary for a PWERM allocation. The resulting estimated fair value of the underlying common stock under the OPM allocation was $[***] ($[***]
post-split) per share on a non-marketable, minority basis.

 The OPM allocates a company’s enterprise value
among the various capital classes. The OPM takes into account the preferred stockholders’ liquidation preferences, participation rights, dividend policy and conversion rights to determine how proceeds from a liquidity event would be distributed
among the various ownership classes at a future date. In determining its enterprise value, the Company used a combination of the following market approaches, each of which were weighted 50%: Guideline Public Company Multiples Method
(“GPCMM”) and Guideline M&A Transaction Multiples Method (“GM&ATM”). For both the GPCMM and GM&ATM analyses, comparative public companies were selected based on business descriptions,
industry, financial size and performance, stock liquidity and management’s recommendations regarding similar public companies. The Company also determined multiples for comparison against the select public companies based on the Company’s
current stage of development. Comparatively, the valuation specialist considered a Discounted Cash Flow (“DCF”) method under the Income Approach leveraging management’s forecast at the time of the valuation. While no
weight was applied to the DCF methodology in the valuation, the results of the calculation approximated the results of the GPCMM and GM&ATM analyses.

The OPM treats common stock and other securities as call options on the enterprise’s value, with exercise prices based on the rights, privileges, and
contractual requirements of the security in question. Under the OPM, the options have value only if the funds available for distribution to stockholders exceed the strike price of the options at the time of a liquidity event. Value derived via the
OPM is estimated by performing an option analysis at each “breakpoint” (i.e. the point at which the exercise price of options is equivalent to the value of the common stock). In the analysis, the Black-Scholes model is used to calculate
the value above each breakpoint in relation to the concluded Company equity value. The Black-Scholes model requires a series of variables, including the enterprise value of the C

CORRESP
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CORRESP

 June 4, 2021

Ms. Julie Sherman

 Ms. Mary Mast

Mr. Alan Campbell

 Ms. Laura Crotty

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of Life Sciences

 100 F Street, N.E.

Washington, D.C. 20549

 Re:  Alpha Teknova, Inc.

        Amendment No. 1 to Draft Registration Statement on Form S-1

         Submitted May 14, 2021

        CIK No. 0001850902

Ladies and Gentlemen:

 This letter responds to
the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Mr. Stephen Gunstream, President and Chief Executive Officer of Alpha Teknova, Inc., a
Delaware corporation (“Teknova” or the “Company”), in the letter dated May 27, 2021 (the “Staff Letter”) regarding the Company’s Amendment No. 1 to Draft
Registration Statement on Form S-1 confidentially submitted to the Commission on May 14, 2021 (the “Amended Draft Registration Statement”). The Company is also concurrently filing
with the Commission a Registration Statement on Form S-1 (the “Registration Statement”). In addition, the Company is sending a copy of this letter and the Registration Statement in
typeset format, including a version that is marked to show changes to the Amended Draft Registration Statement, to the Staff.

 The
numbering of the paragraphs below corresponds to the numbering of the comments in the letter from the Staff. For the Staff’s convenience, the Company has incorporated your comments into this response letter (in bold italics). Page
references in the text of this response letter correspond to the page numbers in the Registration Statement. Capitalized terms used in this letter but otherwise not defined herein shall have the meanings ascribed to such terms in the Registration
Statement.

 Prospectus Summary

 Overview, page
1

1.
 With reference to your revised disclosure on page 106, please revise the Overview section of the
Prospectus Summary to disclose the percentages of your customers that purchase catalog, custom and GMP-grade products, respectively.

Company Response: In response to the Staff’s comment, the Company has revised its disclosure on page 4 to disclose the percentages
of its customers that purchase catalog, custom, and GMP-grade products, respectively.

 June 4, 2021

 Page 2

 Use of Proceeds, page 65

2.
 We note your response to our prior comment 7. Please further revise your disclosure in the prospectus to
provide the detail given in your response letter, which states that although you intend to use the proceeds of the offering for the purposes listed, the company is not able to quantify the approximate amount of the proceeds that will be devoted to
particular uses because it has not made specific determinations regarding the amount or type of any such expenditure, and does not have agreements or commitments for any material acquisitions or investments at this time.

 Company Response: In response to the Staff’s comment, the Company has revised its disclosure on page
65 to indicate that although the Company intends to use the proceeds of the offering for the purposes listed, the Company is not able to quantify the approximate amount of the proceeds that will be devoted to particular uses because it has not made
specific determinations regarding the amount or type of any such expenditure, and does not have agreements or commitments for any material acquisitions or investments at this time.

Business

 Well Positioned in Rapidly Evolving Cell and
Gene Therapy market, page 102

3.
 Your graphic at the top of page 103 indicates that 29% of your accounts are classified as “custom
formulations” and 9% of your accounts are classified as “Clinical Solutions (GMP)”. However, your revised disclosure on page 106 states that 9% of your customers purchased custom products and fewer than 1% purchased GMP-grade products based on cumulative purchase data from 2018 to 2020. Please reconcile your disclosure or advise.

Please also revise to disclose the relevant time periods for the information presented in the graphic.

Company Response: The Company acknowledges the Staff’s comment, and respectfully advises the Staff that the graphic at the top of
page 103 of the Amended Draft Registration Statement relates to customer account data for the 2020 calendar year for those customers of the Company who are active in cell and gene therapy development. Conversely, the disclosure on page 106 of the
Amended Draft Registration Statement relates to customer account data for the 2018 through 2020 calendar years with respect to all of the Company’s customers. In response to the Staff’s comment, the Company has revised the disclosure at
the top of page 104 of the Registration Statement to disclose both the relevant time period and the customer base for the information presented in the graphic.

************

 Thank you for your review of the
filing. Please contact me if you have any further comments or need additional information with respect to the filing. The Company’s future filings will reflect the responses set forth in this letter, as applicable.

 June 4, 2021

 Page 3

 Sincerely,

/s/ Elizabeth A. Razzano

 Paul Hastings LLP

cc:   Stephen Gunstream, Alpha Teknova, Inc.

        Damon Terrill, Alpha Teknova, Inc.

        Jeffrey T. Hartlin, Paul Hastings LLP

United States securities and exchange commission logo
May 27, 2021
Stephen Gunstream
Chief Executive Officer
Alpha Teknova, Inc.
2290 Bert Dr.
Hollister, CA 95023
Re:Alpha Teknova, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted May 14, 2021
CIK No. 0001850902
Dear Mr. Gunstream:
            We have reviewed your amended 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.
Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary
Overview, page 1
1.With reference to your revised disclosure on page 106, please revise the Overview section
of the Prospectus Summary to disclose the percentages of your customers that purchase
catalog, custom and GMP-grade products, respectively.
Use of Proceeds, page 65
2.We note your response to our prior comment 7. Please further revise your disclosure in the
prospectus to provide the detail given in your response letter, which states that although
you intend to use the proceeds of the offering for the purposes listed, the company is not

 FirstName LastNameStephen Gunstream
 Comapany NameAlpha Teknova, Inc.
 May 27, 2021 Page 2
 FirstName LastName
Stephen Gunstream
Alpha Teknova, Inc.
May 27, 2021
Page 2
able to quantify the approximate amount of the proceeds that will be devoted to particular
uses because it has not made specific determinations regarding the amount or type of any
such expenditure, and does not have agreements or commitments for any material
acquisitions or investments at this time.
Business
Well Positioned in Rapidly Evolving Cell and Gene Therapy Market, page 102
3.Your graphic at the top of page 103 indicates that 29% of your accounts are classified as
"custom formulations" and 9% of your accounts are classified as "Clinical Solutions
(GMP)". However, your revised disclosure on page 106 states that 9% of your customers
purchased custom products and fewer than 1% purchased GMP-grade products based on
cumulative purchase data from 2018 to 2020. Please reconcile your disclosure or advise.

Please also revise to disclose the relevant time periods for the information presented in the
graphic.
            You may contact Julie Sherman at 202-551-3640 or Mary Mast at 202-551-3613 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Alan Campbell at 202-551-4224 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Elizabeth A. Razzano

United States securities and exchange commission logo
May 4, 2021
Stephen Gunstream
Chief Executive Officer
Alpha Teknova, Inc.
2290 Bert Dr.
Hollister, CA 95023
Re:Alpha Teknova, Inc.
Draft Registration Statement on Form S-1
Submitted April 5, 2021
CIK No. 0001850902
Dear Mr. Gunstream:
            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 Registration Statement on Form S-1
Cover Page
1.When known, please disclose the Nasdaq stock market tier on which your common stock
will be listed (e.g. Global Select Market, Global Market or Capital Market).
Prospectus Summary
Overview, page 1
2.Your Summary should provide a balanced and factual presentation of your business.
Please revise to discuss your competitive position and the challenges you face in
implementing your business strategy. As a non-exhaustive list of examples only, please
revise to discuss:

 FirstName LastNameStephen Gunstream
 Comapany NameAlpha Teknova, Inc.
 May 4, 2021 Page 2
 FirstName LastNameStephen Gunstream
Alpha Teknova, Inc.
May 4, 2021
Page 2

•Your increase in revenue in 2020 due to the sale of your Sample Transport products,
demand for which could decrease significantly, as discussed on page 19;
•Your reliance on a limited number of customers for a significant portion of your
revenues, as discussed on page 21; and
•Your competitive environment, including the fact that some of your customers may
compete with you and others may develop in-house capabilities, as discussed on page
21.

Additionally, where you discuss your estimated total addressable market on page 2 and in
the Business section, revise to disclose assumptions underlying such estimates and risks
related to these assumptions.
3.We note your statement that you have achieved an annual customer retention rate of
approximately 97% for customers purchasing more than $10,000 worth of your products.
Please revise to clarify what percentage of your customers have an annual spend that
exceeds $10,000 to provide context to the figure.
Implications of Being an Emerging Growth Company and a Smaller Reporting Company, page 6
4.Please supplementally 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.
Our Sponsor, page 6
5.Please tell us why it is appropriate to identify Telegraph Hill Partners Management
Company LLC as your "Sponsor." In this regard, please clarify whether Telegraph Hill
Partners has any duties, obligations or roles beyond those of a controlling stockholder. If
Telegraph Hill Partners does not have any duties or responsibilities to you beyond those of
a controlling stockholder, please revise to refer to Telegraph Hill Partners as your
controlling stockholder.
We depend on a limited number of customers..., page 21
6.We note the risk factor on page 21 which states that for the 2020 Successor Period, your
two largest customers accounted for 15% and 10% of your total revenue, respectively. We
also note your disclosure on page 20 that the substantial majority of your sales are made
on a purchase order basis, which permits your customers to cancel, change or delay their
product purchase commitments with little or no notice. Please clarify whether your two
largest customers proceed on a purchase order basis or whether contractual arrangements
are in place. If so, please file such agreements as exhibits pursuant to Item 601(b)(10) of
Regulation S-K.

 FirstName LastNameStephen Gunstream
 Comapany NameAlpha Teknova, Inc.
 May 4, 2021 Page 3
 FirstName LastNameStephen Gunstream
Alpha Teknova, Inc.
May 4, 2021
Page 3
Use of Proceeds, page 64
7.We note your disclosure that you intend to use portions of the proceeds of this offering to
(i) increase your manufacturing capacity and capabilities, (ii) improve operating
efficiency, (iii) scale up your marketing, sales and R&D staff, (iv) increase brand
awareness, (v) develop new products and services and attract new customers and
(vi) pursue acquisition opportunities. Please specify what amounts will be allocated to
each of these uses.. If any material amounts of other funds are necessary to accomplish the
specified purposes, state the amounts and sources of other funds needed for each specified
purpose and the sources. For guidance, please refer to Item 504 of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 76
8.You state that the increase in Lab Essentials revenue was driven by higher average
revenue per customer and the increase in Clinical Solutions revenue was primarily
attributable to an increased number of customers and higher average revenue per
customer. Please clarify how much of the revenue increase is related to price vs. volume.
Stock-Based Compensation, page 87
9.Once you have an estimated offering price or range, please explain to us how you
determined the fair value of the common stock underlying your equity issuances and the
reasons for any differences between the recent valuations of your common stock leading
up to the IPO and the estimated offering price.  This information will help facilitate our
review of your accounting for equity issuances including stock compensation and
beneficial conversion features. Please discuss with the staff how to submit your response.
Business, page 90
10.We note your focus on the company's ability to quickly and reliably manufacture various
custom and/or GMP-grade products for its customers. With reference to your disclosure at
the bottom of page 100, please revise the Business section, where appropriate, to disclose
the percentage of your customers that purchase custom products and the percentage that
purchase GMP-grade products, as compared to the percentage of your customers that
purchase only stock products.
Increasing Use of mRNA Vaccines and Therapies, page 99
11.Please revise your disclosure in this section to indicate whether you have any contracts or
commercial relationships with customers that are developing mRNA vaccines and
therapies.
Total Addressable Market Opportunity by Segment, page 99
12.We note that the total addressable market opportunities in this section are from a report by

 FirstName LastNameStephen Gunstream
 Comapany NameAlpha Teknova, Inc.
 May 4, 2021 Page 4
 FirstName LastName
Stephen Gunstream
Alpha Teknova, Inc.
May 4, 2021
Page 4
Strategic Directions International ("SDI") that was commissioned by you. Please file
SDI's consent as an exhibit to the registration statement as required by Section 7 of the
Securities Act and Securities Act Rule 436. Alternatively, please tell us why a consent is
not required to be filed.
Government Regulation , page 102
13.We note your disclosure on page 102 indicating that certain of your products are classified
as “medical devices” by the FDA and are subject to FDA oversight. Please revise to
clarify whether all of your GMP-grade products are classified as medical devices and are
therefore subject to the regulations described in this section. To the extent that your GMP-
grade products are subject to different or additional regulations, please revise to describe
the regulatory regime that covers your GMP-grade products or tell us why this disclosure
would not be necessary.
            You may contact Julie Sherman at 202-551-3640 or Mary Mast at 202-551-3613 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Alan Campbell at 202-551-4224 or Laura Crotty at 202-551-7614 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Elizabeth A. Razzano