United States securities and exchange commission logo





                              July 11, 2022

       Maria Zannes
       Chief Executive Officer
       bioAffinity Technologies, Inc.
       22211 W Interstate 10
       Suite 1206
       San Antonio, Texas 78257

                                                        Re: bioAffinity
Technologies, Inc.
                                                            Amendment No.2 to
Registration Statement on Form S-1
                                                            Filed June 16, 2022
                                                            File No. 333-264463

       Dear Ms. Zannes:

             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.

       Amendment No.2 to Registration Statement on Form S-1 Filed June 16, 2022

       Report of Independent Registered Public Accounting Firm, page F-18

   1.                                                   We note you have
included conditional audit reports pending the completion of the
                                                        planned reverse stock
split. Please confirm that you intend to file a pre-effective
                                                        amendment to your Form
S-1 that includes final signed audit reports and signed auditors
                                                        consents prior to
requesting effectiveness.
       Exhibits
       Exhibit 5.1

   2.                                                   Please revise your
legal opinion to clarify that you are opining on all of the common stock
                                                        covered by the
registration statement, as it currently suggests that you are opining only on
 Maria Zannes
bioAffinity Technologies, Inc.
July 11, 2022
Page 2
      the shares of common stock underlying warrants. In addition, please opine
on the Units
      covered by the registration statement. Refer to Sections II.B.1.f and
II.B.1.h of Staff Legal
      Bulletin No. 19.
       You may contact Stephen Kim at 202-551-3291 or Theresa Brillant at
202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Lilyanna Peyser at 202-551-3222 with
any other
questions.



                                                            Sincerely,
FirstName LastNameMaria Zannes
                                                            Division of
Corporation Finance
Comapany NamebioAffinity Technologies, Inc.
                                                            Office of Trade &
Services
July 11, 2022 Page 2
cc:       Wilhelm E. Liebmann, Esq.
FirstName LastName