United States securities and exchange commission logo

                             April 16, 2021

       Andrew Spaventa
       Chief Executive Officer
       Singular Genomics Systems, Inc.
       10931 N. Torrey Pines Road
       Suite #100
       La Jolla, CA 92037

                                                        Re: Singular Genomics
Systems, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted March 22,
                                                            CIK No. 0001850906

       Dear Mr. Spaventa:

              We have reviewed your draft 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 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 comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form S-1 submitted March 22, 2021

       Prospectus Summary
       Overview, page 1

   1.                                                   Please revise your
prospectus summary to include a balanced discussion of your company
                                                        and products. For

                                                              revise to clarify
that you have no experience manufacturing your products in
quantities, conducting sales and marketing activities at scale, or
                                                            managing customer
support at the commercial level;
 Andrew Spaventa
Singular Genomics Systems, Inc.
April 16, 2021
Page 2
                discuss whether any third parties tested or evaluated your
products prior to the beta
              pilot program for the G4 Integrated Solution;
                revise to discuss whether users in the beta pilot program have
achieved the
              performance metrics that are referenced throughout this section;
                disclose that you do not currently intend to seek FDA clearance
for the clinical
              diagnostic use of your products and that your products will be
sold for research use
2.       We note your disclosures here and throughout your document that your
products are
         designed to "empower clinicians", have broad potential application
across "clinical"
         markets, that limitations remain in incorporating current sequencing
technologies and
         products into "routine clinical practice" and similar statements.
However, your disclosure
         on pages 47, 101 and 109 indicates that your products are not designed
as clinical
         diagnostic tests or as medical devices, that you do not intend to
pursue clinical diagnostics
         applications and that your products are labeled for research use only.

         Accordingly, please revise throughout to remove your statements
regarding the potential
         clinical use of your products and the limitations of current
sequencing products in clinical
         practice or advise.
Applications for the G4 Integrated Solution, page 5

3.       Please revise to provide the basis for your statement that HD-Seq
enables higher accuracy
         than existing rare variant detection methods and describe the study in
which you
         demonstrated 99.99% accuracy for 100 base reads with your current
Markets, page 9

4.       Please disclose any material assumptions and limitations associated
with your market
         estimates. Please also revise this section to reflect your disclosure
elsewhere in the
         document that you intend to market your products for research use
Implications of Being an Emerging Growth Company, page 11

5.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
Risk Factors
Our ability to use our net operating loss carryforwards and certain other tax
attributes may be
FirstName LastNameAndrew Spaventa
limited, page 31
Comapany NameSingular Genomics Systems, Inc.
6.     Please
April 16, 2021quantify
                Page 2 your net operating loss carryforwards and research tax
FirstName LastName
 Andrew Spaventa
FirstName   LastNameAndrew    Spaventa
Singular Genomics   Systems, Inc.
April       NameSingular Genomics Systems, Inc.
       16, 2021
April 316, 2021 Page 3
FirstName LastName
Special Note Regarding Forward-Looking Statements, page 61

7.       We note the statement that you undertake no obligation to update
         statements publicly for any reason following the date of the
prospectus. Please revise to
         clarify that you will update this information to the extent required
by law.
Market, Industry and Other Data, page 62

8.       We note your statement that third party information regarding market
and industry data
         has not been independently verified. We further note your statement
that the content of the
         third-party sources, except to the extent set forth in this
prospectus, does not constitute a
         portion of the prospectus. These statements may imply an inappropriate
disclaimer of
         responsibility with respect to such information that appears in your
prospectus. Please
         either delete these statements or specifically state that you are
liable for the information
         related to the market and industry data and your internal company
research that appears in
         the prospectus.
Capabilities of the G4 Integrated Solution, page 92

9.       Please revise your disclosure to describe how the capabilities
referenced in this section
         (e.g. Q30 on greater than 70% of base calls, 4.0 minute cycle time,
150 million reads per
         flow cell) were assessed or observed.
10.      We note your statements that you are "targeting" Q30 for greater than
80% of base calls
         for 150 base reads, 2.5 minute cycle times for each base sequenced (as
compared to a
         current 4.0 minute cycle time) and 330 million reads per flow cell at
commercial launch
         (as compared to demonstrated capability to produce 150 million reads
per flow cell).
         Please revise to briefly discuss the anticipated developments that
will permit you to meet
         these performance goals.
Applications for the G4 Integrated Solution, page 94

11.      Please revise this section to describe the study or trial in which you
generated the data on
         page 95. Please also describe the significance of the "Read 1" and
"Read 2" lines in the
Competitive Strengths, page 102

12.      Please revise to provide the basis for your statement that the G4
Integrated Solution and
         planned PX Integrated Solution offer differentiated performance as
measured by various
         KPIs. To the extent either product has yet to achieve differentiated
performance in these
         indicators in comparative analyses, please revise your disclosure
Intellectual Property, page 107

13.      Please revise to describe the material terms of your license agreement
with The Trustees
 Andrew Spaventa
Singular Genomics Systems, Inc.
April 16, 2021
Page 4
      of Columbia University in the City of New York including:

            the date of the agreement and the identity of each of the parties
to the agreement;
            each parties' rights and obligations under the agreement;
            quantify all payment made to date;
            disclose separately the aggregate amount of all potential
development, regulatory and
          commercial milestone payments;
            disclose the amount of option fees for any additional patents or
intellectual property;
            quantify the royalty rate, or a range no greater than 10 percentage
points per tier;
            disclose when royalty provisions expire, if the expiration is based
on a number of
          years following commercialization, disclose the number of years;
            disclose the expiration date; and
            describe any termination provisions.

      Please also file the agreement as an exhibit to your registration
14.   Please revise to disclose for each material patent and patent application
the specific
      product(s) to which such patents or patent applications relate and the
type of patent
      protection. Please also disclose the jurisdictions of your issued patents
and your European
      patent applications.
       You may contact Ibolya Ignat at 202-551-3636 or Lynn Dicker at
202-551-3616 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alan Campbell at 202-551-4224 or Jeffrey Gabor at 202-551-2544 with any

FirstName LastNameAndrew Spaventa
                                                             Division of
Corporation Finance
Comapany NameSingular Genomics Systems, Inc.
                                                             Office of Life
April 16, 2021 Page 4
cc:       Ryan J. Gunderson, Esq.
FirstName LastName