United States securities and exchange commission logo June 9, 2020 William Hinshaw Chief Executive Officer Axcella Health Inc. 840 Memorial Drive Cambridge, MA 02139 Re: Axcella Health Inc. Registration Statement on Form S-3 Filed June 5, 2020 File No. 333-238983 Dear Mr. Hinshaw: 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 Alan Campbell at 202-551-4224 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Laurie Burlingame