Mail Stop 3030
                                                                 July 27, 2018

     Emily M. Leproust, Ph.D.
     President and Chief Executive Officer
     Twist Bioscience Corporation
     455 Mission Bay Boulevard South, Suite 545
     San Francisco, CA 94158

            Re:     Twist Bioscience Corporation
                    Amendment No. 1 to Draft Registration Statement on Form S-1
                    Submitted July 2, 2018
                    CIK No. 0001581280

     Dear Dr. Leproust:

           We have reviewed your amended 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 response.

           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
     comments.

     Dilution, page 63

     1.     Please expand your revisions added in response to prior comment 6
to clarify how the
            numbers and percentages in the last two columns would change
assuming the exercise of
            all outstanding options and warrants.

     Overview, page 68

     2.     Please reconcile the number of customers disclosed in the last
sentence of the first
            paragraph with the number disclosed on page 71.
 Emily M. Leproust, Ph.D.
Twist Bioscience Corporation
July 27, 2018
Page 2

Business, page 86

3.     Please expand your response to prior comment 10 to clarify how you
determined you
       have only one class of product, given your response and disclosure
regarding four
       product offerings. We note, for example, the statement on page 100 that
you "have four
       primary product categories that address different needs of [y]our
customers across a
       variety of applications."

Management, page 118

4.     Please clarify the dates of Mr. Thorburn's business experience with IXYS
Corporation
       and Televerde.

Index to Consolidated to Financial Statements

Note 2. Summary of significant accounting policies

Customer concentration, page F-9

5.     We note from your response to comment 9 and the revised disclosure on
page 71 that you
       consider parent and subsidiaries to be separate customers if the
subsidiary makes
       payments directly to you and that in fiscal 2017 three of your 286
customers were
       subsidiaries that considered separate customers from their parents.
Please tell us how you
       applied this practice in disclosing the information required by ASC
280-10-50-42. Tell us
       whether the required 10% threshold would have been met if subsidiary and
parent were
       considered one customer.

Note 17. Geographic Information, page F-38

6.     We note your response to comment 25. Please explain to us in detail how
you considered
       the different pricing structures you have in place for your products, as
discussed on your
       website and on pages 100 and 101 of this filing, in concluding that your
product offerings
       are substantially similar based on the criteria outlined in ASC
280-10-50-11 by analogy,
       and therefore separate disclosure of revenues by products is not
required. Describe to us
       in greater detail the similar economic characteristics shared amongst
each of your
       products, including quantitative factors such as similar gross margins
or trends in
       revenue, pricing, and risk of obsolescence. Alternatively, revise to
disclose revenues from
       external customers for each product category under ASC 280-10-50-40.
 Emily M. Leproust, Ph.D.
Twist Bioscience Corporation
July 27, 2018
Page 3

        You may contact Tara Harkins at (202) 551-3639 or Kevin Kuhar,
Accounting Branch
Chief, at (202) 551-3662 if you have questions regarding comments on the
financial statements
and related matters. Please contact Geoff Kruczek at (202) 551-3641 or me at
(202) 551-3528
with any other questions.


                                                          Sincerely,

                                                          /s/ Amanda Ravitz

                                                          Amanda Ravitz
                                                          Assistant Director
                                                          Office of Electronics
and Machinery


cc:    John V. Bautista, Esq.
       Christopher J. Austin, Esq.
       Peter M. Lamb, Esq.