February 1, 2019 Scott Drake President & Chief Executive Officer ViewRay, Inc. 2 Thermo Fisher Way Oakwood Village, OH 44146 Re: ViewRay, Inc. Registration Statement on Form S-3 Filed January 7, 2019 File No. 333-229145 Dear Mr. Drake: 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 Thomas Jones at 202-551-3602 with any questions. Sincerely, Division of Corporation Finance Office of Electronics and Machinery cc: Robert McCormack