October 28, 2024

Fawwad Qureshi
Chief Financial Officer
Trupanion, Inc.
6100 4th Avenue S, Suite 200
Seattle, WA 98108

       Re: Trupanion, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           File No. 001-36537
Dear Fawwad Qureshi:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2023
Revenue, page 46

1.     We note your disclosure on page 45 describing your revenue streams,
including
       subscription fees, writing policies on behalf of third parties, and
insurance software
       solutions. We also note your disclosures elsewhere in the filing that
reference
       revenues, such as but not limited to commissions (page 40), gross
underwriting
       premiums (page 40), and sign-up fees (page 45). To help investors better
understand
       your results of operation and the underlying reasons for material
changes in
       quantitative and qualitative terms, please revise your future filings to
address the
       items below. See Item 303 of Regulation S-K.
           Enhance your discussion of revenues to better define your different
revenue
           streams. For example, define    subscription fees    and
premiums,    distinguishing
           between the two, if applicable, and explain all key revenue streams
for each
           segments    business.
           Where applicable, provide additional details regarding material
revenue drivers
           for the periods presented and the business(es) to which these apply.
For example,
 October 28, 2024
Page 2

          if commissions and premiums are material contributors to subscription
and / or
          other business revenues, separately quantify and discuss trends for
these items.
Note 10. Reserve for Veterinary Invoices, page 80

2.     We note your disclosures on page 81 that period-over-period favorable
and
       unfavorable development for the subscription and other business segments
is
       attributable to ongoing analysis of recent payment trends. In future
filings, please
       enhance your disclosures to include more detail on recent payment
trends, and to
       provide more detailed discussion, with quantification, of
period-over-period changes
       and trends in claim severity, frequency, average settlement time or
other underlying
       drivers.
3.     We note your inclusion of    Non-cash expenses    in your reserve
roll-forwards on page
       81. In future filings, please provide a definition and explanation of
what these
       amounts represent.
Note 15. Segments, page 88

4.     We note your disclosure that the Company has two aggregated reporting
segments
       and, further, that the subscription business segment consists of
products that have
       similar target margin profiles. Please clarify for us if the Company has
       multiple operating segments that aggregate into the two reportable
segments and, if
       so, provide us with a summary of the Company's identified operating
segments. To
       the extent that the Company is aggregating or combining multiple
operating segments
       in determining your reportable segments pursuant to ASC 280-10-50-10
through 50-
       13, provide us with your aggregation analysis. In your analysis, please
compare and
       contrast the similarity of the economic characteristics between the
aggregated
       operating segments, and address each of the areas listed in ASC
280-10-50-11a to
       11e.


        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact Cara Lubit at 202-551-5909 or Robert Klein at
202-551-3847 with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Finance