United States securities and exchange commission logo





                         November 16, 2020

       Kamal Adawi
       Chief Financial Officer
       Exagen Inc.
       1261 Liberty Way
       Vista, California 92081

                                                        Re: Exagen Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed November 10,
2020
                                                            File No. 333-250015

       Dear Mr. Adawi:

              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 Abby
Adams at (202) 551-6902 with any questions.




                         Sincerely,


                         Division of Corporation Finance

                         Office of Life Sciences
       cc:                                              Matthew T. Bush, Esq.