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                             June 11, 2021

       Nima Ghamsari
       Head of Blend
       Blend Labs, Inc.
       415 Kearny Street
       San Francisco, California 94108

                                                        Re: Blend Labs, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted May 28,
2021
                                                            CIK No. 0001855747

       Dear Mr. Ghamsari:

              We have reviewed your amended draft registration statement 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 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 comment applies 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 this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless otherwise noted, where prior comments are referred to
they refer to our letter
       dated May 11, 2021.

       Amendment No. 1 to Draft Registration Statement on Form S-1/A Submitted
May 28, 2021

       Notes to Unaudited Pro Forma Condensed Combined Financial Statements,
page 94

   1.                                                   We note your revised
presentation described in "(X)" in response to prior comment 10.
                                                        Please revise to
clarify that the number of shares of common stock in this calculation does
                                                        not include those
shares to be issued in this offering.
 Nima Ghamsari
FirstName
Blend Labs,LastNameNima Ghamsari
            Inc.
Comapany
June       NameBlend Labs, Inc.
     11, 2021
June 11,
Page 2 2021 Page 2
FirstName LastName
        You may contact Melissa Kindelan, Senior Staff Accountant, at (202)
551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have
questions regarding the
comment on the financial statements and related matters. Please contact Anna
Abramson, Staff
Attorney, at (202) 551-4969 or Jeff Kauten, Staff Attorney, at (202) 551-3447
with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:      Rezwan D. Pavri, Esq.