August 29, 2025
VIA EDGAR TRANSMISSION
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. Conlon Danberg
| Re: | Accuray Incorporated Registration Statement on Form S-3 Registration No. 333-288998 |
Dear Mr. Danberg:
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 S-3 (File No. 333-288998) (the “Registration Statement”) of Accuray Incorporated. We respectfully request that the Registration Statement be declared effective as of 9:00 A.M. Eastern Time on September 2, 2025 or as soon as practicable thereafter, or at such other time as our legal counsel, Davis Polk & Wardwell LLP, may request by a telephone call to the staff of the U.S. Securities and Exchange Commission.
Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Davis Polk & Wardwell LLP, by calling Alan F. Denenberg at (650) 752-2004.
[Signature page follows]
Very truly yours,
| Accuray Incorporated | ||
| By: | /s/ Jesse Chew | |
| Name: | Jesse Chew | |
| Title: | Senior Vice President, Chief Legal Officer and Corporate Secretary | |
[Signature Page to Acceleration Request]