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                              July 14, 2020

       Todd Ford
       Chief Financial Officer
       Coupa Software Inc
       1855 S. Grant Street
       San Mateo, CA 94402

                                                        Re: Coupa Software Inc
                                                            Form 10-K for the
Year Ended January 31, 2020
                                                            Filed March 20,
2020
                                                            Form 10-Q for the
Quarter Ended April 30, 2020
                                                            Filed June 8, 2020
                                                            File No. 001-37901

       Dear Mr. Ford:

              We have reviewed your June 30, 2020 response to our comment
letter 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       June 16, 2020 letter.

       Form 10-Q for the Quarter Ended April 30, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP, page 38

   1.                                                   We note from your
response to prior comment 5 that you intended to present adjusted free
                                                        cash flow as a
performance measure. Given the naming of this measure, the nature of the
                                                        adjustments, and the
GAAP measure to which you are reconciling, adjusted free cash flow
                                                        appears to be a
liquidity measure. Explain further why you believe a measure titled
                                                           adjusted free cash
flow    with adjustments for capital expenditures is a performance
                                                        measure or revise your
future filings to appropriately identify this as a liquidity measure.
                                                        Refer to Question
102.07 of the non-GAAP C&DIs.
 Todd Ford
Coupa Software Inc
July 14, 2020
Page 2
Form 10-K for the Year Ended January 31, 2020
Management's Discussion and Analysis of Financial Condition and Results of
Operation
Results of Operations, page 51

2.       We note your response to prior comment 4. Please clarify for us what
you mean by
         "customer contracts" in your proposed revised disclosures. In this
regard, tell us whether
         this refers to contracts with new customers only or whether it also
refers to new contracts
         with existing customers. If it is the former and new customers are
contributing
         significantly to your revenue growth, then please tell us why you do
not disclose your
         customer count in your quarterly Form 10-Q filings. To the extent
customer count refers
         to contracts from both new and existing customers, please tell us the
amount of revenue
         growth attributable to new versus existing customers in fiscal 2020
and in the first quarter
         of fiscal 2021. Also, revise to include a quantified discussion of
such factors in future
         filings, if material.
      You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 with any questions.



FirstName LastNameTodd Ford                                    Sincerely,
Comapany NameCoupa Software Inc
                                                               Division of
Corporation Finance
July 14, 2020 Page 2                                           Office of
Technology
FirstName LastName