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                              June 25, 2020

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

                                                        Re: Accolade, Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed June 24, 2020
                                                            File No. 333-236786

       Dear Mr. Singh:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our June
19, 2020 letter.

       Amendment No. 2 to Form S-1 filed June 24, 2020

       The Offering, page 15

   1.                                                   It appears the number
of common stock to be outstanding after the offering disclosed on
                                                        page 15 and elsewhere
is based on the actual number outstanding on February 29, 2020,
                                                        whereas on page 17 and
elsewhere it is based on the actual number outstanding on May
                                                        31, 2020. Please revise
your disclosure to consistently present the number of shares
                                                        expected to be
outstanding after the offering, as appropriate.
       Capitalization, page 70

   2.                                                   In view of the
estimated offering price range that has been assumed in the filing, please
 Rajeev Singh
Accolade, Inc.
June 25, 2020
Page 2
         tell us (and revise your disclosure as appropriate) which automatic
conversion condition
         for your convertible preferred stock disclosed on page F-25 is
operable.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Quarterly Results of Operations
Quarterly Trends, page 93

3.       Refer to your response to prior comment 1. Please explain to us why
the change in the
         form of the fiscal 2020 bonus payment from cash to fully vested stock
options decreased
         the amount of the related expense. In this regard, tell us whether and
to what extent the
         fair value of the option awards were lower than the cash awards, the
factors contributing
         to such difference, the per share amount upon which the fair value of
the stock options
         was based and the basis for the per share amount used.
       You may contact Keira Nakada at (202) 551-3659 or Doug Jones at (202)
551-3309 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Eric Envall at (202) 551-3234 or Dieter King at (202) 551-8071 with any
other questions.



FirstName LastNameRajeev Singh                                Sincerely,
Comapany NameAccolade, Inc.
                                                              Division of
Corporation Finance
June 25, 2020 Page 2                                          Office of Trade &
Services
FirstName LastName