February 26, 2020

Harry Stylli, Ph.D.
Chief Executive Officer
Progenity, Inc
4330 LaJolla Village Drive, Suite 200
San Diego, CA 92122

       Re: Progenity, Inc.
           Draft Registration Statement on Form S-1/A
           Amended on February 14, 2020
           CIK No. 0001580063

Dear Dr. Stylli:

        We have reviewed your amended draft registration statement and have the
comment. 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

Draft Registration Statement on Form S-1, amended on February 14, 2020

New Product Development, page 84

1.     We note your response to prior comment nine, and the revision made at
page 84 of your
       amended filing. Please revise to identify which components of the
regulatory approval
       pathway constitute, or may constitute, key development milestones for
your product
       You may contact Eric Atallah, Staff Accountant, at 202-551-3663, or Lisa
Staff Accountant, at 202-551-3614, if you have questions regarding comments on
the financial
statements and related matters. Please contact Paul Fischer, Staff Attorney, at
202-551-3415, or
Celeste M. Murphy, Legal Branch Chief, at 202-551-3257, with any other
 Harry Stylli, Ph.D.
Progenity, Inc
February 26, 2020
Page 2

FirstName LastNameHarry Stylli, Ph.D.
                                        Division of Corporation Finance
Comapany NameProgenity, Inc
                                        Office of Life Sciences
February 26, 2020 Page 2
cc:       Branden C. Berns, Esq.
FirstName LastName