June 24, 2019

Zane Burke
Chief Executive Officer
Livongo Health, Inc.
150 West Evelyn Ave., Suite 150
Mountain View, CA 94041

       Re: Livongo Health, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted June 14, 2019
           CIK 0001639225

Dear Mr. Burke:

      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. Unless we note otherwise, our references to prior comments are to
comments in our
June 6, 2019 letter.

Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted June 14,
2019

Our Market Opportunity, page 5

1.     We note your response to comment 2 regarding how you calculated the
market
       opportunity for diabetes and hypertension. Please disclose in the filing
the material
       assumptions described in your response.
Livongo Health, Inc. Financial Statements
Note 10. Stock-Based Compensation, page F-35

2.     We may have additional comments on your accounting for equity issuances,
including
       stock options, share issuances, award modifications and other
share-based transactions.
 Zane Burke
Livongo Health, Inc.
June 24, 2019
Page 2
      Once you have an estimated offering price, please provide us an analysis
explaining the
      reasons for the differences between recent valuations used for your
share-based
      transactions leading up to the IPO and the estimated offering price.
Also, disclose in Note
      17 the terms of the share-based issuances subsequent to March 31, 2019.
      You may contact Rufus Decker at 202-551-3769 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Jonathan Burr at 202-
551-5833 or Brigitte Lippmann at 202-551-3713 with any other questions.



                                                           Sincerely,

FirstName LastNameZane Burke                               Division of
Corporation Finance
                                                           Office of Beverages,
Apparel and
Comapany NameLivongo Health, Inc.
                                                           Mining
June 24, 2019 Page 2
cc:       Mark Baudler
FirstName LastName