June 18, 2025

Kevin Feeley
Chief Financial Officer
GeneDx Holdings Corp.
333 Ludlow Street
North Tower
6th Floor
Stamford, Connecticut 06902

       Re: GeneDx Holdings Corp.
           Form 10-K for Fiscal Year Ended December 31, 2024
           Form 10-Q for Fiscal Quarter Ended March 31, 2025
           File No. 001-39482
Dear Kevin Feeley:

       We have reviewed your filings and have the following comment.

       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-Q for the Quarterly Period Ended March 31, 2025
Financial Statements
Note 14. Segment Reporting, page 20

1.     We note that you have identified one reportable segment, GeneDX, and the
CODM
       evaluates segment performance based on revenue and adjusted gross
profit. We
       also note the reported segment revenue of GeneDX is consistent with
consolidated
       revenue for the three months ended March 31, 2025. Please address the
following:
           If you have identified a single operating segment, tell us whether
it is managed on
           a consolidated basis or other than consolidated basis, and fully
explain how you
           reached that determination.
           If your single operating segment is managed on a consolidated basis,
tell us how
           you determined adjusted gross profit, and not consolidated net
income, is the
           measure required to be reported. In this regard, if the CODM uses
more than one
           measure of a segment   s profit or loss in assessing segment
performance and
 June 18, 2025
Page 2

           deciding how to allocate resources, the measure required to be
reported is that
           which management believes is determined in accordance with the
measurement
           principles most consistent with those used in measuring the
corresponding
           amounts in the consolidated financial statements. See ASC
280-10-50-4, ASC
           280-10-50-28A, and ASC 280-10-55-15D.
             If you have identified multiple operating segments that have been
aggregated into
           a single reportable segment, please describe each operating segment
and revise
           your disclosure to indicate that operating segments have been
aggregated. See
           ASC 280-10-50-21(a).


        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 Tayyaba Shafique at 202-551-2110 or Jeanne Baker at
202-551-3691 if
you have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services
cc:   Tayyaba Shafique