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                           November 25, 2020

       David Baszucki
       President and Chief Executive Officer
       Roblox Corporation
       970 Park Place
       San Mateo, California 94403

                                                        Re: Roblox Corporation
                                                            Registration
Statement on Form S-1
                                                            Filed November 19,
2020
                                                            File No. 333-250204

       Dear Mr. Baszucki:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 5, 2020 letter.

       Registration Statement on Form S-1

       Prospectus Summary
       Overview, page 1

   1.                                                   You state in your
response to prior comment 8 that management's focus is primarily on
                                                        the growth and
engagement of your users. Considering a substantial majority of your
                                                        revenue is dependent
upon users becoming paying users, please explain further why
                                                        paying users is not a
key metric in managing your business. At a minimum, revise your
                                                        disclosures here to
balance your discussion of DAUs with information regarding the
                                                        number of daily paying
users for each period presented.
 David Baszucki
FirstName LastNameDavid Baszucki
Roblox Corporation
Comapany 25,
November  NameRoblox
              2020     Corporation
November
Page 2    25, 2020 Page 2
FirstName LastName
Our Developers and Creators, page 4

2.       You refer to the number of developers and creators that earned Robux
on the Roblox
         Platform. You also indicate that developers and creators can convert
earned Robux into
         real-world currency. Please revise to describe how you define "earned
Robux" and clarify
         whether the 960,000 of developers and creators referenced here all
earned Robux that can
         be converted into real-world currency. To the extent developers and
creators earn Robux
         that are not convertible into real-world currency, tell us the number
of such developers
         and revise to explain how amounts paid to such developers and creators
impact your
         results of operations.
Dilution, page 75

3.       It appears from your response to prior comment 4 that you have
included deferred costs in
         both your historical and pro forma net tangible book value
calculations. Tell us how you
         determined that deferred contract costs are tangible assets for
purposes of your dilution
         calculation, or revise.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Our Business Model, page 84

4.       We note you removed the measures of adjusted EBITDA and adjusted
EBITDA as a
         percentage of bookings in response to prior comment 5; however, it
appears that you
         have replaced such information with the chart on page 87. Please
explain further how you
         determined the amounts for each of the cost components used in such
chart and explain
         how these compare to the total operating costs included in your
financial statements. In
         this regard, you state that each of the categories is exclusive of
depreciation and stock-
         based compensation and yet the total of the costs components included
in the chart
         exceeds total operating expenses for each period presented. Please
explain. Also, revise
         your discussion of the individual costs to provide the amount of such
costs for each period
         presented.
Key Factors Affecting Our Performance, page 90

5.       Please revise your chart at the top of page 92 to clearly label the
age groups presented by
         each of the three corresponding colors.
6.       Please revise your description of the User Cohort Analysis charts on
page 94 to clearly
         explain what data is reflected in the charts, how it is calculated,
and what the charts
         demonstrate.
Comparison of the nine months ended September 30, 2019 and 2020
Revenue, page 101

7.       In your response to prior comment 8, you indicate that you will
disclose the percentage of
         the increase in your revenue attributable to new paying users versus
existing paying users.
 David Baszucki
Roblox Corporation
November 25, 2020
Page 3
         It does not appear, however, that you have provided this information.
Please revise to
         include this data.
Note 1 - Overview and Summary of Significant Accounting Policies
Revenue Recognition, page F-11

8.       We note your response to prior comment 15. Please provide us with a
specific and
         comprehensive analysis of how you considered ASC 606-10-25-21 in
determining that the
         virtual currency, virtual goods and hosting services could be
combined.
9.       In your response to prior comment 15 you indicate that the time
between the purchase of
         virtual currency and the conversion of that currency into virtual
goods is very short,
         usually occurring on the same day. Please revise your disclosures to
incorporate this
         information.
10.      In your response to prior comment 16 you indicate that the payment
processors do not
         track data associated with the conversion of the virtual currency into
virtual goods. Please
         explain further the role of the payment processor as it relates to the
conversion of virtual
         currency. In this regard, it would appear that a user purchases the
currency through a
         payment processor but separately converts the currency into a virtual
good within the
         company's platform. Also, please explain further why you are unable to
track whether a
         user purchases consumable or durable virtual goods and tell us what
information you are
         able to obtain from your system. In your response, explain why you
have not yet
         developed your systems to track such information. Finally, tell us how
you know what
         amount to pay your developers and creators given your apparent system
limitations.
11.      You state in your response to prior comment 16 that virtual goods are
"generally"
         purchased and used across "most experiences" on your platform. Please
describe for us,
         and provide examples of, those goods that can be used across all
experiences versus those
         that are limited to certain games. Also, specifically quantify for us
the extent to which
         virtual goods are used across multiple games and if and how this might
change. Finally
         please further discuss why you believe it is appropriate to recognize
virtual goods that are
         used in just one game or only in games created by the same developer
on a gross basis.
Developer Exchange Fees, page F-14

12.      We note your response to prior comment 20. Please tell us how you
account for situations
         in which a developer or creator is not permitted to exchange Robux for
real world
         currency.
Note 14 - Subsequent Events, page F-34

13.    Please
FirstName      revise to disclose
            LastNameDavid         the value of the RSUs granted in November
2020 as well as the
                              Baszucki
       related unrecognized compensation expense. Refer to ASC 855-10-50-2(b).
Also, revise to
Comapany NameRoblox Corporation
       describe the type of liquidity events that will satisfy the performance
conditions for these
November    25, 2020 Page 3
       awards.
FirstName LastName
 David Baszucki
FirstName LastNameDavid Baszucki
Roblox Corporation
Comapany 25,
November  NameRoblox
              2020     Corporation
November
Page 4    25, 2020 Page 4
FirstName LastName
General

14.      We have received your supplemental submission dated November 12, 2020
in which you
         provide your analysis to support your belief that Robux digital
currency is not a security.
         We are reviewing your submission and will contact you if we have any
comments.
        You may contact Melissa Kindelan, Staff Accountant, at (202) 551-3564
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Matthew
Crispino, Staff Attorney,
at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology