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                             May 24, 2024

       Nicholas Woodman
       Chief Executive Officer
       GoPro, Inc.
       3025 Clearview Way
       San Mateo, California

                                                        Re: GoPro, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2023
                                                            Filed February 9,
2024
                                                            Form 10-Q for
Fiscal Quarter Ended March 31, 2024
                                                            Filed May 7, 2024
                                                            Response Dated May
7, 2024
                                                            File No. 001-36514

       Dear Nicholas Woodman :

              We have reviewed your May 7, 2024 response to our comment letter
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. Unless
       we note otherwise, any references to prior comments are to comments in
our April 10, 2024
       letter.

       Form 10-Q for Fiscal Quarter Ended March 31, 2024

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Critical Accounting Policies & Estimates
       Impairment of Goodwill, page 37

   1.                                                   With regards to our
prior comment 1, please tell us how you considered the first quarter
                                                        developments discussed
in footnote 9, including the increased and accelerated costs
                                                        associated with your
future product strategy and roadmap, an increasingly competitive
                                                        environment,
integration and product development costs related to the recent acquisition
                                                        of Forcite Helmet
Systems and restructuring, in your assessment of goodwill.
 Nicholas Woodman
GoPro, Inc.
May 24, 2024
Page 2
Non-GAAP Financial Measures , page 40

2.       We note your response to comment 2. Please tell us how you calculated
the income tax
         adjustments related to the non-GAAP financial measures. It appears
that your non-GAAP
         adjustment for the deferred tax valuation allowance removes the
effects of the valuation
         allowance from your GAAP tax provision and appears to change your
income taxes
         recognition method, resulting in an individually tailored accounting.
Please remove this
         adjustment from your reconciliation. Refer to Question 100.04 of the
Non-GAAP
         Financial Measures Compliance and Disclosure Interpretations.

       Please contact Christie Wong at 202-551-3684 or Julie Sherman at
202-551-3640 if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,
FirstName LastNameNicholas Woodman
                                                            Division of
Corporation Finance
Comapany NameGoPro, Inc.
                                                            Office of
Industrial Applications and
May 24, 2024 Page 2                                         Services
FirstName LastName