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                              May 24, 2024

       Kate Bueker
       Chief Financial Officer
       HubSpot, Inc.
       Two Canal Park
       Cambridge, MA 02141

                                                        Re: HubSpot, Inc.
                                                            10-K filed February
14, 2024
                                                            File No. 001-36680

       Dear Kate Bueker :

              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

       Notes to Consolidated Financial Statements
       Note 2. Summary of Significant Accounting Policies
       Investments, page 75

   1.                                                   Please tell us and
revise future filings to clarify how your impairment policy for debt
                                                        investments classified
as available-for-sale securities complies with the guidance in ASC
                                                        326-30-35. In this
regard, we note your policy involves making a determination as to
                                                        whether the unrealized
loss is other-than-temporary. Provide us with your analysis of the
                                                        materiality of the
impact from any correction of your policy.
       Leases, page 77

   2.                                                   You indicate that
operating lease liabilities and related expenses are recorded as incurred
                                                        for short-term leases.
Please tell us and revise future filings to clarify how your policy
                                                        complies with the
guidance in ASC 842-20-25-2 that, although variable lease payments
                                                        should be recognized as
incurred, lease payments should be recognized on a straight-line
                                                        basis over the lease
term.
 Kate Bueker
HubSpot, Inc.
May 24, 2024
Page 2
3.    We note your disclosure that the net present value of future lease
payments is determined
      using the Company   s incremental borrowing rate because your operating
leases do not
      provide an implicit rate. Tell us how your determination of the discount
rate for the lease
      complies with the guidance in ASC 842-20-30-3. That is, even though your
operating
      leases do not provide an implicit rate, explain whether the rates
implicit in any of your
      leases are readily determinable from information provided in the lease.
Stock-Based Compensation, page 80

4.    We note your disclosure that stock-based compensation costs for awards
with
      performance conditions is recognized on the graded vesting attribution
method over the
      requisite service period. Please tell us and disclose in future filings
what consideration
      was given to the guidance in ASC 718-10-30-28 that compensation costs for
awards with
      performance conditions should be recognized if and when it is probable
that the
      performance target will be achieved.
       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 Melissa Walsh at 202-551-3224 or Stephen Krikorian at
202-551-3488
with any questions.



                                                            Sincerely,
FirstName LastNameKate Bueker
                                                            Division of
Corporation Finance
Comapany NameHubSpot, Inc.
                                                            Office of
Technology
May 24, 2024 Page 2
cc:       Alyssa Harvey Dawson
FirstName LastName