December 26, 2018

G. Bradley Cole
Chief Financial Officer
Genomic Health, Inc.
301 Penobscot Drive
Redwood City, CA 94063

       Re: Genomic Health, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Form 8-K filed on November 6, 2018
           File No. 000-51541

Dear Mr. Cole:

       We have limited our review of your filings to the financial statements
and related
disclosures 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 8-K filed on November 6, 2018

Exhibit 99.1, page 1

1.    We note your presentation of Non-GAAP income (loss) from operations and
Non-GAAP
      net income (loss) includes adjustments for certain research and
development expenses
      recognized in connection with your activities associated with Biocartis.
Please tell us how
      you determined these adjustments do not substitute individually-tailored
income or
      expense recognition methods for those of GAAP. Refer to question 100.04
of the
      Division's Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
2.    Please tell us whether you have included the tax effects on the
adjustments presented to
      arrive at Non-GAAP net income (loss). To the extent these adjustments are
disclosed net
      of taxes, please revise to present the effect of income taxes as a
separate adjustment and
      expand your disclosure to clearly explain how the tax effects of non-GAAP
adjustments
      are calculated. Refer to Question 102.11 of the Division's Non-GAAP
Financial Measures
      Compliance and Disclosure Interpretations.
 G. Bradley Cole
Genomic Health, Inc.
December 26, 2018
Page 2

       In closing, 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.

      You may contact Brian McAllister at (202) 551-3341 or Craig Arakawa at
(202) 551-
3650 with any questions.



                                                          Sincerely,
FirstName LastNameG. Bradley Cole
                                                          Division of
Corporation Finance
Comapany NameGenomic Health, Inc.
                                                          Office of Beverages,
Apparel and
December 26, 2018 Page 2                                  Mining
FirstName LastName