ALGNAlign Technology

You disclose that determining the standalone selling price, allocation of consideration from the contract to the individual performance obligations and the appropriate timing of revenue recognition is the result of significant qualitative and quantitative judgments. You also identify a variety of factors that you consider, which may vary over time.

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Please tell us how your disclosure is consistent with ASC 606-10-50-1(b) as it relates to the disclosure of quantitative information related to your significant judgments and changes in judgments. As part of your response, please address how your disclosure meets the objective of the disclosure requirements of Topic 606.

Align Technology Inc. (“Align”) acknowledges receipt of your comment letter dated March 31, 2022 (the "Comment letter") with respect to the above-referenced filing. As discussed with the Staff on April 12, 2022, the Company respectfully requests an extension to respond to the Comment Letter in order to provide sufficient time for the Company to prepare the necessary response. The Company is committed to responding to the Comment Letter promptly and intends to provide a response to the Staff no later than April 22, 2022. We are grateful for the Staff's assistance in this matter.

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In the meantime, if the Staff has any questions, please do not hesitate to contact me at (408) 470-1006.

Yours truly,

/s/ John F. Morici

John F. Morici

Chief Financial Officer and Executive Vice President, Global Finance

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We have reviewed your response to prior comment 1 and note that you estimate usage, which requires significant judgment. For each of the periods presented, please tell us your estimated usage rates. If multiple types of estimated usage rates are used, please explain how these were determined. In addition, tell us the approximate impact to revenue from any period over period changes in estimated usage rates.

Align Technology Inc. (“Align”) acknowledges receipt of your comment letter dated April 29, 2022 (the "Comment letter") with respect to the above-referenced filing. As discussed with the Staff on May 11, 2022, the Company is grateful for the Staff's extension to respond to the Comment letter by May 27, 2022, to provide sufficient time for the Company to prepare the necessary response. In the meantime, if the Staff has any questions, please do not hesitate to contact me at (408) 470-1006.

Yours truly,

/s/ John F. Morici

John F.

Rest of the answer

Morici

Chief Financial Officer and Executive Vice President, Global Finance

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