November 9, 2018 Randall S. Eslick President and Chief Executive Officer Bank of Commerce Holdings 555 Capitol Mall, Suite 1255 Sacramento, CA 95814 Re: Bank of Commerce Holdings Registration Statement on Form S-4 Filed November 7, 2018 File No. 333-228243 Dear Mr. Eslick: 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 David Gessert at 202-551-2326 with any questions. Sincerely, Division of Corporation Finance Office of Financial Services