April 7, 2020

Paul Davis
Director
XRAY-TWOLF HoldCo Corporation
3025 Orchard Parkway
San Jose, California 95134

       Re: XRAY-TWOLF HoldCo Corporation
           Amendment No. 1 to Registration Statement on Form S-4
           Filed March 26, 2020
           File No. 333-236492

Dear Mr. Davis:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our March 16,
2020 letter.

Amendment No. 1 to Form S-4 filed March 26, 2020

Exclusive Forum, page 190

1.     We note your response to comment 8. Please disclose whether the
exclusive forum
       provision applies to actions arising under the Exchange Act. Please also
describe any
       risks to investors, including, but not limited to, increased costs to
bring a claim and that
       these provisions can discourage claims or limit investors' ability to
bring a claim in a
       judicial forum that they find favorable. In addition, please revise to
address whether there
       is any question as to whether a court would enforce the provision. If
the provision does
       not apply to actions arising under the Exchange Act, please also ensure
that the governing
       documents state this clearly, or tell us how you will inform investors
in future filings that
       the provision does not apply to any actions arising under the Exchange
Act.
 Paul Davis
XRAY-TWOLF HoldCo Corporation
April 7, 2020
Page 2

       You may contact Melissa Gilmore, Staff Accountant, at (202) 551-3777 or
Melissa
Raminpour, Accounting Branch Chief, at (202) 551-3379 if you have questions
regarding
comments on the financial statements and related matters. Please contact Sherry
Haywood, Staff
Attorney, at (202) 551-3345 or Erin Purnell, Staff Attorney, at (202) 551-3454
with any other
questions.



FirstName LastNamePaul Davis                              Sincerely,
Comapany NameXRAY-TWOLF HoldCo Corporation
                                                          Division of
Corporation Finance
April 7, 2020 Page 2                                      Office of
Manufacturing
FirstName LastName