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                              June 10, 2021

       Todd Nelson
       President and Chief Executive Officer
       Codex DNA, Inc.
       9535 Waples Street, Suite 100
       San Diego, CA 92121

                                                        Re: Codex DNA, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed May 28, 2021
                                                            File No. 333-256644

       Dear Mr. Nelson:

              We have reviewed your 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.

       Registration Statement on Form S-1 filed May 28, 2021

       Results of Operations, page 70

   1.                                                   We note your response
to comment 1 and your revised disclosure on page 71 that NEB
                                                        has agreed to pay the
Company a royalty in the low double digits. Please revise your
                                                        disclosure to give
investors a reasonable idea of the amount of the royalty rate that does
                                                        not exceed ten
percentage points.
   2.                                                   We note that the
confidential settlement agreement with New England Biolabs includes a
                                                        settlement payment.
Please disclose the amount of the settlement payment or explain to
                                                        us why such disclosure
is not required.

              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
 Todd Nelson
Codex DNA, Inc.
June 10, 2021
Page 2

action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Julie Sherman at 202-551-3640 or Al Pavot at
202-551-3738 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Tom Kluck at 202-551-3233 or Celeste Murphy at 202-551-3257 with any
other
questions.



                                                           Sincerely,
FirstName LastNameTodd Nelson
                                                           Division of
Corporation Finance
Comapany NameCodex DNA, Inc.
                                                           Office of Life
Sciences
June 10, 2021 Page 2
cc:       Philip Oettinger
FirstName LastName