May 3, 2019 Saundra Pelletier President and Chief Executive Officer Evofem Biosciences, Inc. 12400 High Bluff Drive, Suite 600 San Diego, CA 92130 Re: Evofem Biosciences, Inc. Registration Statement on Form S-3 Filed April 30, 2019 File No. 333-231126 Dear Ms. Pelletier: 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 Joseph McCann at (202) 641-4264 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance