February 26, 2025

David Miller
Chief Financial Officer
Champions Oncology, Inc.
1 University Plaza
Suite 307
Hackensack, New Jersey 07601

       Re: Champions Oncology, Inc.
           Form 10-K for the Fiscal Year Ended April 30, 2024
           Form 8-K dated December 11, 2024
           File No. 001-11504
Dear David Miller:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended April 30, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations - Oncology Services Revenue, page 18

1.     We note your disclosure regarding the decrease in oncology services
revenue for the
       year ended April 30, 2024 compared to the prior annual period. Your
explanation for
       this decrease uses terminology and metrics that are not otherwise
defined, such as net
       bookings and available convertible revenue. Please revise your future
filings to define
       such terminology and clearly correlate these metrics to significant
revenue
       fluctuations. Please also disaggregate your major sources of revenue for
each period
       presented.
 February 26, 2025
Page 2
Research and Development, page 18

2.     Please revise your disclosure in future filings to quantify the
significant components
       of your research and development expenses for each period presented.
Form 8-K dated December 11, 2024
Exhibit 99.1
Non-GAAP Financial Information, page 4

3.     We note you present non-GAAP financial measures of Non-GAAP net income
(loss),
       Non-GAAP net income (loss) per share, and Adjusted EBITDA. We further
note
       your various references to Adjusted EBITDA on pages one and two without
reference
       to the most directly comparable GAAP measure. Please revise your future
disclosures
       to comply with Item 10(e)(1)(i) of Regulation S-K. Specifically address
the
       following:
           Revise to present your GAAP measures with equal or greater
prominence than
           your non-GAAP measures; and
           Provide a reconciliation of Adjusted EBITDA to the most directly
comparable
           financial measure calculated in accordance with GAAP.

        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.

       Please contact Bonnie Baynes at 202-551-4924 or Angela Connell at
202-551-3426
with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Life
Sciences