January 8, 2020

Jacob Chacko, M.D.
President and Chief Executive Officer
Oric Pharmaceuticals, Inc.
240 E. Grand Ave, 2nd Floor
South San Francisco, CA 94080

       Re: Oric Pharmaceuticals, Inc.
           Draft Registration Statement on Form S-1
           Submitted December 13, 2019
           CIK No. 0001796280

Dear Dr. Chacko:

       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.     We note your references throughout your registration statement to your
product candidates
       as potentially "first-in-class." This term suggests that your product
candidates are
       effective and likely to be approved. Further, it is inappropriate for
you to state or imply
       that you will achieve a given market share given the length of time and
uncertainty with
       respect to securing marketing approval for your product candidates.
Please delete these
       references. If your use of this term was intended to convey your belief
that the products
       are further along in the development process, you may discuss that you
are not aware of
       competing products that are further along in the development process.
Statements such as
 Jacob Chacko, M.D.
Oric Pharmaceuticals, Inc.
January 8, 2020
Page 2
         these should be accompanied by cautionary language that the statements
are not intended
         to give any indication that the product candidates have been proven
effective or that they
         will receive regulatory approval.
2.       Your pipeline table appears to include every in-house development
program. Please
         revise the table to include only those programs that are material to
the company. If you
         believe that every program listed is material, please provide us with
an analysis explaining
         your belief. In particular, to the extent your lead optimization
program is material to the
         company, please discuss this in your analysis.
3.       We note your reference to Drs. Sawyers and Lowe as "founders." We also
note your
         website describes Dr. Sawyers as a member of your Scientific Advisory
Board and Dr.
         Lowe as a consultant. Please revise the Prospectus Summary and other
         sections of the registration statement to clearly explain the extent
of your "founders"
         involvement with your company including contractual relationships. In
your revised
         disclosure, please also explain what it means to be a "founder." A
"founder" who is not a
         principal stockholder or employee does not appear to have a current
connection to the
         company. In this regard, please explain whether Drs. Sawyers and Lowe
has maintained
         or transferred their initial interest and other rights in the company.
4.       We note that your lead product candidate, ORIC-101, builds on academic
work from Dr.
         Sawyers laboratory at Memorial Sloan Kettering Cancer Center. Please
clarify the nature
         and scope of any engagement with Dr. Sawyers and/or Memorial Sloan
Kettering Cancer
         Center to include what entitlement, if any, you have to intellectual
property deriving from
         Dr. Sawyers and/or Memorial Sloan Kettering Cancer Center.
Our strategy, page 5

5.       We note your strategy to "[r]apidly" advance your lead product
candidate through clinical
         development. Please revise your disclosure and similar statements
throughout your
         registration statement to remove any implication that you will be
successful in
         commercializing your product candidates in a rapid or accelerated
manner as these
         statements are speculative for you to make.
Risk Factors
Intellectual property discovered through government funded programs may be
subject to federal
regulations..., page 62

6.     We note that you may be subject to federal regulations such as march-in
rights. Please
       provide additional disclosure regarding:
         the technology or technologies subject to march-in rights;
FirstName LastNameJacob Chacko, M.D. would be affected by the exercise of
march-in rights;
         the portion of your business that
Comapany andNameOric Pharmaceuticals, Inc.
January  8, 2020 Page 2 how you may be compensated in the event such rights are
            whether and
FirstName LastName
 Jacob Chacko, M.D.
FirstName LastNameJacob Chacko, M.D.
Oric Pharmaceuticals, Inc.
January 8, NameOric Pharmaceuticals, Inc.
Page 3
January 8, 2020 Page 3
FirstName LastName
Market, industry and other data, page 78

7.       Please delete the statement that you have not separately verified data
from third parties or
         revise your disclosure to specifically state that you are liable for
the data included in the
         registration statement.
Use of proceeds, page 79

8.       Please expand your disclosure to specify the intended use of proceeds,
including the
         amount you intend to allocate to ORIC-201 and the other research and
         activities, individually. Additionally, please revise to state how far
the net proceeds are
         expected to allow you to continue in the development for each of your
         candidates. Refer to Item 504 of Regulation S-K.
Managements discussion and analysis of financial condition and results of
Critical accounting policies and significant judgments and estimates
Stock-based compensation , page 97

9.       Once you have an estimated offering price or range, please explain to
us the reasons for
         any differences between the recent valuations of your common stock
leading up to the
         initial public offering and the estimated offering price. This
information will help facilitate
         our review of your accounting for equity issuances including stock
compensation and
         beneficial conversion features.
GR antagonist program: ORIC-101, page 104

10.      We note that you have developed a proprietary immunohistochemistry
(IHC) assay that
         measures GR protein expression levels as well as a proprietary GR gene
         signature that measures GR signaling activity, both of which are being
utilized in your two
         ongoing Phase 1b clinical trials of ORIC-101. On page 32, you note
that the FDA has
         required marketing approval of all companion diagnostic tests for
cancer therapies. In the
         business section, please revise your disclosure to explain how
approval of your diagnostic
         tools for ORIC-101 impacts the timing of approval and/or
commercialization of ORIC-
         101. Please also disclose the impact to approval and/or marketing of
ORIC-101 if the
         diagnostic tool is not approved.
Background on cancer resistance, page 107

11.      Please revise your discussion of innate resistance to clearly provide
that basis for your
         belief that innate resistance targets have a "higher probability of
technical success than
         other cancer targets" and "the potential for rapid clinical
development and approval
 Jacob Chacko, M.D.
FirstName LastNameJacob Chacko, M.D.
Oric Pharmaceuticals, Inc.
January 8, NameOric Pharmaceuticals, Inc.
Page 4
January 8, 2020 Page 4
FirstName LastName
The glucocorticoid receptor as a mechanism of resistance, page 113

12.      At first use, please provide a brief explanation of the disclosed
p-value and how it is used
         to measure statistical significance. Please also explain the relevance
of statistical
         significance to the FDA's evidentiary standards for drug approval.
ORIC-101 differentiation, page 115

13.      We note that you conducted a series of in vitro experiments evaluating
         mifepristone and relacorilant with determinations of more favorable,
comparable, or less
         favorable. Please provide context for these studies by providing the
specific details and
         parameters of the studies from which this data was drawn, including
endpoints, duration
         of treatment, comparison against placebo or standard treatment,
metrics utilized, statistical
         significance, etc. Without this contextual information, it may be
difficult for the reader to
         draw an accurate and balanced assessment of these favorable results.
If you cannot
         provide this information, please remove these comparisons.
Our collaboration and license agreements, page 130

14.      We note your disclosure that you have entered into agreements with
Memorial Sloan
         Kettering Cancer Center and Washington University in St. Louis. To the
extent that these
         agreements are material, please describe the material terms and file
them as exhibits to the
         registration statement, or tell us why this is not required. See Item
601(b)(10) of
         Regulation S-K.
Intellectual property, page 132

15.      We note that you have licensed certain pending patents from Memorial
Sloan Kettering
         Cancer Center. Please amend your disclosure to discuss the material
terms of this license
         agreement. In your description of this agreement you should
specifically identify, to the
         extent material:
           each party s rights and obligations;
           nature and scope of intellectual property transferred if the
agreement involves a
           duration of agreement and royalty term, if applicable;
           termination provisions; and
           payment provisions.

         In addition, please file the agreement as an exhibit to your
registration statement as
         required under Item 601(b)(10) of Regulation S-K.
16.      Please revise your disclosure to identify the applicable foreign
jurisdictions for your
         pending patent applications.
 Jacob Chacko, M.D.
FirstName LastNameJacob Chacko, M.D.
Oric Pharmaceuticals, Inc.
January 8, NameOric Pharmaceuticals, Inc.
Page 5
January 8, 2020 Page 5
FirstName LastName
Executive compensation, page 157

17.      Please update your disclosure to include the disclosures required by
Item 402 of
         Regulation S-K for your last completed fiscal year.

18.      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.
       You may contact Ibolya Ignat at 202-551-3636 or Kevin Vaughn at
202-551-3494 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jeffrey Gabor at 202-551-2544 or Celeste Murphy at 202-551-3257 with
any other


                                                               Division of
Corporation Finance
                                                               Office of Life
cc:      Melissa Rick, Esq.