September 12, 2019

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention:		Kathleen Collins, Accounting Branch Chief Rebekah Lindsey, Staff Accountant
	Re:	Zuora, Inc.
		Form 10-K for Fiscal Period Ended January 31, 2019
		Filed April 14, 2019
		Form 10-Q for the Quarterly Period Ended April 30, 2019
		Filed June 11, 2019
		File No. 001-38451

Ladies and Gentlemen:

In your letter dated September 9, 2019 (the “Staff Comment Letter”), you requested that Zuora, Inc. (the “Company”) respond to your comments within ten business days (the “Initial Response Date”) or advise when it would provide a response.

Per our telephone conversation on September 11, 2019, on behalf of the Company, we advised that due to the proximity of the receipt of the Staff Comment Letter and the Initial Response Date to the Company’s quarter end review process and the filing of its Form 10-Q for the quarterly period ended July 31, 2019, the Company confirms that it will file a response by October 4, 2019.

Thank you for your consideration. Please do not hesitate to contact me at (650) 335-7613 if you have any questions.

Securities and Exchange Commission

September 12, 2019

Page 2

Sincerely,

/s/ Ran D. Ben-Tzur    

Ran D. Ben-Tzur

cc:

Tien Tzuo, Chairman of the Board of Directors and Chief Executive Officer

Tyler R. Sloat, Chief Financial Officer

Jennifer W. Pileggi, Senior Vice President, General Counsel, and Secretary

Zuora, Inc.

Gordon K. Davidson, Esq.

Fenwick & West LLP