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                             September 19, 2022

       Jason Kelly, Ph.D.
       Chief Executive Officer
       Ginkgo Bioworks Holdings, Inc.
       27 Drydock Avenue
       8th Floor
       Boston, MA 02210

                                                        Re: Ginkgo Bioworks
Holdings, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 7,
2022
                                                            File No. 333-267315

       Dear Dr. Kelly:

              We have limited our review of your registration statement to
those issues we have
       addressed in our comment. In our comment, 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 comment applies 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 the comment, we may have additional comments.

       Registration Statement on Form S-1 filed September 7, 2022

       General

   1.                                                   Please revise to
include financial statements of Zymergen Inc. pursuant to Item 11(e) of
                                                        Form S-1 or tell us why
you believe inclusion of such financial statements is not required.
                                                        Additionally, disclose
in the summary a more fulsome description of the proposed merger,
                                                        including the
approximate percentage of issued and outstanding shares of Zymergen held
                                                        by shareholders who
have entered into voting agreements to vote in favor of the merger.
               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.
 Jason Kelly, Ph.D.
Ginkgo Bioworks Holdings, Inc.
September 19, 2022
Page 2

       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.

      Please contact Christine Westbrook at 202-551-5019 or Joe McCann at
202-551-
6262 with any questions.



                                                           Sincerely,
FirstName LastNameJason Kelly, Ph.D.
                                                           Division of
Corporation Finance
Comapany NameGinkgo Bioworks Holdings, Inc.
                                                           Office of Life
Sciences
September 19, 2022 Page 2
cc:       Marko S. Zatylny, Esq.
FirstName LastName