United States securities and exchange commission logo April 17, 2023 Jaisim Shah Chief Executive Officer & President Scilex Holding Company 960 San Antonio Road Palo Alto, CA 94303 Re: Scilex Holding Company Registration Statement on Form S-1 Filed April 10, 2023 File No. 333-271204 Dear Jaisim Shah: 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 Cindy Polynice at 202-551-8707 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Jeff Hartlin, Esq.