United States securities and exchange commission logo





                             October 13, 2020

       Rajeev Singh
       Chief Executive Officer
       Accolade, Inc.
       1201 Third Avenue, Suite 1700
       Seattle, WA 98101

                                                        Re: Accolade, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted October
9, 2020
                                                            CIK No. 0001481646

       Dear Mr. Singh:

                                                        This is to advise you
that we do not intend to review your registration statement.

               We request that you publicly file your registration statement no
later than 48 hours prior
       to the requested effective date and time. 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 Cara
Wirth at (202) 551-7127 with any questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Trade & Services
       cc:                                              Colleen Badgley