United States securities and exchange commission logo





                           July 30, 2021

       Rathna Girish Mathrubootham
       Chief Executive Officer
       Freshworks Inc.
       2950 S. Delaware Street, Suite 201
       San Mateo, CA 94403

                                                        Re: Freshworks Inc.
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted July 19,
2021
                                                            CIK No. 0001544522

       Dear Mr. Mathrubootham:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. References to prior comments are to those in our letter dated
July 12, 2021.

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Prospectus Summary
       Overview, page 1

   1.                                                   Please refer to prior
comment 1. To avoid giving undue prominence to a total customer
                                                        population that
contains customers you are not focused on growing and who you have
                                                        stated do not
meaningfully contribute to your financial success, please revise your
                                                        prospectus summary to
also disclose the number of customers with over $5,000 in ARR
                                                        along with their
contribution to total ARR for each period presented, as previously
                                                        requested.
 Rathna Girish Mathrubootham
FirstName
FreshworksLastNameRathna  Girish Mathrubootham
            Inc.
Comapany
July       NameFreshworks Inc.
     30, 2021
July 30,
Page  2 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Performance, page 70

2.       Refer to prior comment 4. Since acquiring new customers is a key
factor affecting your
         business, as previously requested, please revise here in MD&A to
provide your customer
         count for each reported period.
       You may contact Rebekah Lindsey, Senior Staff Accountant, at (202)
551-3303 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have
questions regarding
comments on the financial statements and related matters. Please contact Anna
Abramson, Staff
Attorney, at (202) 551-4969 or Jeff Kauten, Staff Attorney, at (202) 551-3447
with any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:      Sepideh Mousakhani