United States securities and exchange commission logo March 29, 2021 Harry Stylli, Ph.D. Chairman and Chief Executive Officer Progenity, Inc. 4330 La Jolla Village Drive, Suite 200 San Diego, CA 92122 Re: Progenity, Inc. Registration Statement on Form S-1 Filed March 19, 2021 File No. 333-254471 Dear Dr. Stylli: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Tim Buchmiller at (202) 551-3635 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Ryan A. Murr, Esq.