December 5, 2019

Christian Gormsen
Chief Executive Officer
Eargo, Inc.
1600 Technology Drive, 6th Floor
San Jose, CA 95110

       Re: Eargo, Inc.
           Draft Registration Statement on Form S-1
           Submitted November 8, 2019
           CIK No. 0001719395

Dear Mr. Gormsen:

       We have reviewed your 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
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

Draft Registration Statement on Form S-1

Prospectus Summary
Overview, page 1

1.     Please revise your disclosure to provide objective support for your
statements that
       your Eargo hearing aids are the "first and only" virtually invisible,
       rechargeable, completely-in-canal, FDA regulated, exempt Class I device
for the treatment
       of hearing loss and a "first-of-its-kind product" or revise these
statements to make it clear
       that they are management's beliefs.
Key Advantages of Our Solution, page 7

2.     We note your disclosure that your average net promoter score (NPS) was
over 45 for the
 Christian Gormsen
FirstName LastNameChristian Gormsen
Eargo, Inc.
Comapany5, 2019
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         period from June 2018 to September 30, 2019. Please put this number
into perspective for
         investors and discuss why you view an NPS score of 45 as a positive
indicator. Please
         also revise this section to include a cross-reference to your
discussion of NPS on page 64.
Implications of Being an Emerging Growth Company, page 9

3.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
Use of Proceeds, page 65

4.       Please revise your use of proceeds section to indicate the approximate
amount of the
         proceeds intended to be used for each purpose that you have disclosed.
Refer to Item 504
         of Regulation S-K.
Managements discussion and analysis of financial condition and results of
Overview, page 74

5.       We note you have sold over 25,000 Eargo hearing aid systems as of
September 30, 2019.
         Please clarify whether this number is net of returns.
Factors affecting our business
Return rate, page 75

6.       Please expand your disclosure to identify the primary underlying
reasons your customers
         are returning the purchased products. In addition, describe the
reasons your return rate
         declined during 2019.
Results of operations
Revenue, net, page 78

7.       You disclose that revenue increased due to increased lead conversion
and the
         commencement of sale of the Eargo Max hearing aids. Please tell us
what "lead
         conversion" means and expand your disclosure to clarify the reason for
the increased lead
         conversion and the reason the Max drove your sales higher.
Critical accounting policies and estimates
Stock-based compensation
Fair value of common stock, page 85

8.       Once you have an estimated offering price or range, please explain to
us how you
         determined the fair value of the common stock underlying your equity
issuances and the
         reasons for any differences between the recent valuations of your
common stock leading
         up to the IPO and the estimated offering price. This information will
help facilitate our
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Eargo, Inc.
Comapany5, 2019
December NameEargo, Inc.
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         review of your accounting for equity issuances including stock
compensation and
         beneficial conversion features.
Overview, page 88

9.       Please provide the basis for your statement on page 89 that you have
achieved a "high
         level of consumer satisfaction."
Overview of Hearing Loss, page 91

10.      Please revise the pie chart and bar graphs on this page to better
differentiate the levels of
         hearing loss severity.
Intellectual Property, page 112

11.      Please revise to specify the products, product groups and technologies
to which your
         patents relate, the type of patent protection you have, whether you
own or license the
         patents, the foreign jurisdictions where you currently have patents or
patent applications
         and the expiration dates for your most material patents.
Principal Stockholders, page 139

12.      Please revise your disclosure to identify the natural person or
persons who have voting
         and investment control of the shares held by Future Fund Investment
Company No.4 Pty
         Ltd, Pivotal Alpha Limited and The Charles and Helen Schwab Living
Trust U/A DTD
         11/22/1985 if Charles and Helen Schwab are not the trustees.
Consolidated financial statements
Notes to the consolidated financial statements
2. Summary of significant accounting policies, page F-7

13.      Under concentration of credit risk you disclose that 45% of your
accounts receivable are
         from a third-party financing partner as of year-end. Please provide an
accounting policy
         for transactions involving your financing partner. In addition,
describe any impact this
         arrangement has on your accounting for revenue.
14.      We note from your website that you offer for a fee a one-time
replacement for lost or
         damaged items "not related to normal use." Please disclose how you
account for
         this "loss and damage policy," and provide us any necessary additional
       You may contact Michael Fay at 202-551-3812 or Sasha Parikh at
202-551-3627 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ada D. Sarmento at 202-551-3798 or Celeste Murphy at 202-551-3257 with
any other
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Eargo, Inc.
December 5, 2019
Page 4

FirstName LastNameChristian Gormsen
                                      Division of Corporation Finance
Comapany NameEargo, Inc.
                                      Office of Life Sciences
December 5, 2019 Page 4
cc:       Alan C. Mendelson, Esq.
FirstName LastName