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                             January 15, 2021

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

                                                        Re: Roblox Corporation
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed January 8,
2021
                                                            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.

       Amendment to Registration Statement on Form S-1

       Capitalization, page 72

   1.                                                   Please revise the
second bullet point in the introductory paragraph to clarify that in
                                                        addition to the
349,522,440 preferred shares outstanding at September 30, 2020, the 11.6
                                                        million of Series H
stock will also convert into Class A shares upon effectiveness. Similar
                                                        revisions should be
made to footnote (1) on page 13. Also, include a discussion regarding
                                                        the share exchange of
Class A to Class B common stock in November 2020. Lastly,
                                                        update the number of
Class A common shares outstanding on a pro forma basis as of
                                                        September 30, 2020, as
noted below the table.
 David Baszucki
Roblox Corporation
January 15, 2021
Page 2
Note 1. Overview and Summary of Significant Accounting Policies
Revenue Recognition, page F-11

2.    Based upon your response letters dated November 12, 2020 and December 1,
2020, and a
      telephone conversation on December 15, 2020, we are unable to concur with
your
      conclusion that you provide a significant service of integrating the
virtual currency,
      associated virtual goods, and online experience (e.g., social graphs,
chat function) to
      create one persistent output for the user. Therefore, based on the
information provided,
      we do not believe that you should recognize revenue over a 23 month
estimated user life
      for a combined performance obligation to provide an enhanced integrated
gaming
      experience that includes access to the games and experiences on the
Platform, holding and
      using virtual currency, and acquiring, using, and holding virtual goods.
Please reconsider
      your conclusions and revise your registration statement and financial
statements as
      appropriate.
Note 14. Subsequent Events (unaudited), page F-35

3.    We note that the conversion terms of the convertible preferred stock were
amended in
      conjunction with the Series H preferred issuance. Please revise here to
clarify that all
      outstanding convertible preferred shares will automatically convert
similar to the Series H
      preferred shares.
        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,
FirstName LastNameDavid Baszucki
                                                           Division of
Corporation Finance
Comapany NameRoblox Corporation
                                                           Office of Technology
January 15, 2021 Page 2
cc:       Michael E. Coke
FirstName LastName