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                         February 26, 2021

       Robert Reffkin
       Founder and Chief Executive Officer
       Compass, Inc.
       90 Fifth Avenue, 3rd Floor
       New York, New York 10011

                                                        Re: Compass, Inc.
                                                            Amendment No 1 to
Draft Registration Statement on Form S-1
                                                            Submitted February
12, 2021
                                                            CIK No. 0001563190

       Dear Mr. Reffkin:

             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
February 5, 2021.

       Amendment No 1.

       Key Business Metrics and Non-GAAP Financial Measures, page 16

   1.                                                   Please revise your
non-GAAP presentations throughout the filing to address any
                                                        prominence over
comparable GAAP results. See Item 10(e)(1)(i)(A) of Regulation S-K
                                                        and the Division of
Corporation Finance, Non-GAAP Compliance & Disclosure
                                                        Interpretation 102.10.
 Robert Reffkin
FirstName LastNameRobert Reffkin
Compass, Inc.
Comapany26,
February   NameCompass,
            2021        Inc.
February
Page 2 26, 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operation Key
Business Metrics, page
Our Business Model, page 64

2.       In your response to prior comment 8 you indicate that it is important
to highlight Platform
         Contribution as potential investors are likely to utilize this metric
to measure the
         performance of and value the Company. Please clarify why this is an
appropriate measure
         of the Company   s performance when it appears to exclude significant
operating expenses
         that are necessary to generate your revenue. We also note the measure
excludes by adding
         back non-cash stock-based compensation with no apparent explanation.
In your
         clarification and any revision please address the Commission's
disclosure expectations and
         required consideration of the regulatory disclosure frameworks of GAAP
and non-GAAP
         Measures in the Commission Guidance On Management's Discussion and
Analysis of
         Financial Condition and Operations, Release 33-10751.
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-14

3.       We note your response to prior comment 17. Please tell us how you
considered the
         following in your determination that you control the services prior to
being transferred to
         the client and that the agent is fundamentally performing services on
your behalf and
         under your direction. Revise your disclosures as appropriate.

                Clarify if you enter into contracts with clients and commit to
provide them services
              prior to an agent being identified and agreeing to fulfill the
service. If so, clarify how
              frequently. In this regard, your response indicates that agents
primarily source their
              own clients.

                In your response you state that in certain jurisdictions the
agent representing the
              Company is named in the contract. Clarify if this creates a
contractual relationship
              between the agent and the client, or if there are any other
separate contracts entered
              into between the agent and the client.

                In your response you indicate that you employ personnel known
as    brokers of
              record    who are responsible to the State licensing authorities
for the conduct by the
              Company   s agents under State licensing laws and regulation and
that this supports
              that the Company is the principal in the transaction. Please
further clarify how this
              gives you the right to direct the services performed by the
agents as you see fit and
              have the right to direct them to fulfill specific contracts. In
this regard, in your
              response you state that your agents primarily source their own
clients and have the
              right to decline to accept a client.

                In your response you state that the fact that the Company
enters into the contract with
              the client supports that the Company is the principal in the
transaction. Please clarify
 Robert Reffkin
Compass, Inc.
February 26, 2021
Page 3
           your contractual responsibility for the acceptability of services
and if there are any
           other parties the client can seek remedies from. If you are solely
responsible for
           remedies sought by clients, clarify if you have the contractual
right to pursue claims
           against agents to recoup any remedies you provide to clients.
Further, based on your
           disclosures in your Business section, it appears that your agents
are primarily
           responsible for performing the majority of the services necessary to
fulfill the
           contract. As such, please clarify how you are primarily responsible
for fulfillment.

             In your response you state that agents have flexibility in
adjusting commission rates
           within guidelines. As such, it appears that they have some price
discretion. Clarify
           the extent to which they are able to adjust rates, and how you
considered the
           significance to your revenue.
Consolidated Financial Statements
Notes to Financial Statements
10. Stock Based Compensation, page F-34

4.     When your preliminary IPO price is known, please provide us with a
reconciliation that
       explains the differences between the fair values of your common stock as
determined on
       each grant date, including the difference between the most recent grant
date fair value and
       the midpoint of your offering range. Describe the objective evidence
that supports your
       determination of the fair value of your common stock at each grant date.
Please provide
       this analysis for the most recent six months. In addition, your
disclosure should fully
       describe and explain the appropriateness of the assumptions and methods
utilized at the
       IPO valuation date that are significantly different than those used in
the most recent
       valuation.
       You may contact Laura Veator, Staff Accountant, at (202) 551-3716 or
Craig Wilson,
Senior Advisor, at (202) 551-3226 if you have questions regarding comments on
the financial
statements and related matters. Please contact Matthew Crispino, Staff
Attorney, at (202) 551-
3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.



                                                            Sincerely,
FirstName LastNameRobert Reffkin
                                                            Division of
Corporation Finance
Comapany NameCompass, Inc.
                                                            Office of
Technology
February 26, 2021 Page 3
cc:       Jamie Evans
FirstName LastName