Goldman Sachs & Co. LLC

200 West Street

New York, NY 10282

J.P. Morgan Securities LLC

383 Madison Avenue

New York, NY 10179

Jefferies LLC

520 Madison Avenue

New York, NY 10022

March 22, 2021

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:       SEMrush Holdings, Inc.

Registration Statement on Form S-1 (File No. 333-253730)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as the representatives of the several underwriters (the “Representatives”), hereby join in the request of SEMrush Holdings, Inc. a Delaware corporation (the “Company”), that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time on March 24, 2021, or as soon thereafter as practicable. We, the undersigned Representatives, confirm that the underwriters are aware of their obligations under the Securities Act.

Pursuant to Rule 460 under the Securities Act, we advise you that as of the date hereof, we and the several underwriters have distributed approximately 6,000 copies of the Company’s Preliminary Prospectus dated March 16, 2021 to prospective underwriters, institutional investors, dealers and others.

We, the undersigned Representatives, hereby represent that we are in compliance and will comply, and have been informed by the other participating underwriters that they are in compliance and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering pursuant to the above-referenced Registration Statement and Preliminary Prospectus.

[Signature Page Follows]

Very truly yours,
Goldman Sachs & Co. LLC
J.P. Morgan Securities LLC
Jefferies LLC,
As Representatives of the several Underwriters
GOLDMAN SACHS & CO. LLC
By:	/s/ Rebecca Steinthal
	Name:	Rebecca Steinthal
	Title:	Managing Director
J.P. MORGAN SECURITIES LLC
By:	/s/ Ilana Foni
	Name:	Ilana Foni
	Title:	Managing Director
JEFFERIES LLC
By:	/s/ Gaurav Kittur
	Name:	Gaurav Kittur
	Title:	Managing Director

[Signature Page to Underwriters’ Acceleration Request Letter]