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                                                            July 17, 2025

Mark D. Mordell
Chief Executive Offcier
Avidbank Holdings, Inc.
1732 North First Street
6th Floor
San Jose, CA 95112

       Re: Avidbank Holdings, Inc.
           Amendment No. 2 to the Draft Registration Statement on Form S-1
           Submitted July 9, 2025
           CIK No. 0001443575
Dear Mark D. Mordell:

     We have reviewed your amended draft registration statement and have the
following
comment.

       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 the comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our July 2, 2025 letter.

Amendment No. 2 to the Draft Registration Statement on Form S-1
Summary, page 1

1.     We note your response to prior comment 1 on pages 12-13 and 105-107 and
your
       statement that loans are categorized to banking divisions based on
product type and
       source of repayment, and that the nature and stage of the borrower's
business are not
       material to this classification. However, your response does not clearly
explain how
       the company determines the appropriate category for borrowers that
exhibit
       characteristics common to more than one division. For example, with a
view to
       revised disclosure, advise us whether a VC-funded technology or other
company
 July 17, 2025
Page 2

       could also fit in the Specialty Finance division if it receives accounts
receivable
       lending or if a VC-funded company might also meet the criteria for
Corporate
       Banking if characteristics of the product type or source of repayment
overlap with that
       division. Also with a view to disclosure, advise us to what extent
subjectivity is
       involved in making these determinations and, if so, what criteria are
used.
       Please contact John Spitz at 202-551-3484 or Cara Lubit at 202-551-5909
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Finance
cc:   Craig Miller
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