March 22, 2019

Joseph J. Beneducci
Chairman, President and Chief Executive Officer
ProSight Global, Inc.
412 Mt. Kemble Avenue
Suite 300
Morristown, NJ 07960

       Re: ProSight Global, Inc.
           Amendment No. 1 to
           Draft Registration Statement on Form S-1
           Filed March 8, 2019
           CIK No. 0001634038

Dear Mr. Beneducci:

      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.

Amendment No. 1 to DRS on Form S-1

Letter From Joe Beneducci, Founder and CEO, page i

1.     We acknowledge your response to prior comment 1 and the corresponding
revised
       disclosures. However, Mr. Beneducci's brief introductory statement must
present a
       balanced discussion of your business. The letter continues to refer to
your business as
       "profitable," and the financial strength of a top-tier insurance company
without balancing
       information. As previously noted, please expand on your statements to
explain how your
       technology-based platform allows for growth beyond industry standards,
how the
       insurance industry remains "unsettled," and how you are responding to
customer needs
 Joseph J. Beneducci
FirstName LastNameJoseph J. Beneducci
ProSight Global, Inc.
Comapany2019
March 22, NameProSight Global, Inc.
March 22, 2019 Page 2
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         "on an entirely different level." Additionally, balance the statement
of nearly $900
         million of annual premiums with quantified information about your
expenses during the
         period and revise the last paragraph on the "A New Type of Hybrid
Insurance Company"
         to clarify your statement that your business is profitable by
clarifying that it was profitable
         in 2018 but was not profitable in previous years.
Market, Industry and Other Data, page v

2.       We acknowledge your revised disclosures in response to prior comment
2, but your
         statement that third party information regarding market and industry
data has not been
         independently verified implies a disclaimer of responsibility with
respect to
         such information. Please either delete the statement or specifically
state that you are liable
         for the information related to the market and industry data.
Prospectus Summary
Our Competitive Strengths, page 4

3.       We note your deleted statements in response to prior comment 4.
However, you continue
         to assert in the first bullet on page 6 and elsewhere that you are
"not weighed down
         by outdated legacy infrastructure like many other insurance carriers,"
and in the first bullet
         on page 5 that your ProSight Climber GPS application is a competitive
advantage because
         it allows you to monitor and review your underwriting and reserving
decisions on a real-
         time basis. Similarly, you continue to state on page 96 that you can
develop flexible,
         customer facing solutions more rapidly than your competitors. As
previously stated,
         please provide the basis for your statements that the rest of the
industry relies on obsolete
         systems and that other companies in the industry are not able to
inform underwriting
         decisions on a real time basis.
Our Strategy, page 7

4.       Please revise to restore the definition of the term "MGU."
Risk Factors, page 8

5.       We refer to your revised disclosures in response to prior comment 6,
and note that the
         discussion of the positive aspects of your strengths and strategies
continue to be more
         prominent, detailed and focused on your business than the expanded
discussion of your
         risks. Please further revise to provide more balance with respect to
content and
         presentation. Additionally, expand your penultimate bullet on page 10
to explain that
         you will continue to be a controlled company following the offering,
and that in
         connection with this offering, you will enter into a new Stockholders'
Agreement with
         your principal stockholders, which will, among other items, provide
that Goldman and
         TPG together will be able to designate four of your nine directors, as
you disclose on page
         138.
 Joseph J. Beneducci
FirstName LastNameJoseph J. Beneducci
ProSight Global, Inc.
Comapany2019
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Our amended and restated certificate of incorporation provides that the Court
of Chancery...,
page 47

6.       We note your revised disclosures in response to prior comment 10 that
the provision will
         not apply to claims which are vested in the exclusive jurisdiction of
a court or forum other
         than the Delaware Chancery Court, including suits to enforce
liabilities or duties created
         by the Exchange Act. However, Section 22 of the Securities Act creates
concurrent
         jurisdiction for federal and state courts over all suits brought to
enforce any duty or
         liability created by the Securities Act or the rules and regulations
thereunder. Please
         disclose whether this provision applies to actions arising under the
Securities Act. If the
         provision applies to claims arising under the Securities Act, also
disclose that there is
         uncertainty with respect to whether a court would enforce this
provision, and that
         stockholders will not be deemed to have waived your compliance with
the federal
         securities laws and the rules and regulations thereunder. If this
provision does not apply
         to actions arising under the Securities Act, please ensure that the
exclusive forum
         provision in your governing documents and the related filing
disclosure states this clearly.
Financial Condition
Equity-based compensation, page 76

7.       As previously requested in prior comment 13, bullet point 3, please
tell us whether and, if
         so, how you used the assistance of any third-party valuation
specialist with regards to your
         valuation of RSU and P share awards.
8.       You disclose on page 126 that upon the completion of this offering, a
percentage of
         unvested P Shares will vest based on the net proceeds received by the
principal
         stockholders and the initial public offering price and that vested P
Shares will convert into
         shares of ProSight Global in connection with the merger of PGHL into
ProSight Global.
         Please tell us your consideration of this transaction with regards to
your Capitalization
         disclosures on page 49.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Estimates
Reserves for unpaid losses and LAE, page 82

9.       Your disclosure on page 84 added in response to prior comment 15
merely provides
         estimates of the impact of various percentage changes applied to the
net ultimate incurred
         losses and ALAE for each of the last three accident years and all
preceding accident years
         in the aggregate. It is unclear from this disclosure whether or how
the disclosed impacts
         (either individually or in the aggregate) represent reasonably likely
changes in your
         reserves for unpaid losses and LAE. In this regard, we note that your
net prior year
         development in each of the prior three years is significantly below
the absolute value of
         the aggregate favorable or unfavorable development depicted in your
sensitivity analysis.
         Please revise your disclosure to provide a sensitivity analysis that
depicts the impact of the
 Joseph J. Beneducci
FirstName LastNameJoseph J. Beneducci
ProSight Global, Inc.
Comapany2019
March 22, NameProSight Global, Inc.
March 22, 2019 Page 4
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FirstName LastName
         reasonably likely changes in the underlying factors inherent in your
most recent estimate
         of reserves for unpaid losses and LAE or revise your disclosure to
indicate how your
         current presentation depicts the aggregate impact of reasonably likely
changes in your
         reserve estimates.
Executive Compensation
Outstanding Equity Awards at Fiscal Year-End, page 127

10.      Please revise your amended table by expanding footnote 1 to explain
whether this offering
         is expected to meet the terms of such a transaction.
Unpaid Losses, page F-33

11.      We acknowledge your response to prior comment 20. Please address the
following
         additional comments:
           Although you disclose $5.0 million of favorable prior year
development in 2018, your
            explanation of the lines causing this development net to a $13.8
million favorable
            impact. It is apparent from your All Other claims development table
on page F-39 that
            significant unfavorable development relates to the 2016 and 2017
accident years from
            these lines. Given that the $8.8 million difference between your
consolidated favorable
            development and the aggregate causes you disclose is greater that
the consolidated
            development itself, revise your disclosure to identify and further
explain the remaining
            $8.8 million in unfavorable development.
           It appears that your revised disclosures could be further enhanced
to explain the
            specific reasons for the increase or decrease experienced in the
lines/niches indicated
            for each year reported. For example, you noted that the $16.5
million adverse
            development in the General Liability line primarily related to 2013
to 2015 accident
            years due to higher than expected liability severities in the
Construction and Media
            lines of business. Disclose the specific reasons as to what caused
the Construction and
            Media lines to incur higher severity.
11. Insurance Operations
Incurred and Paid Claims Development
All Other, page F-39

12.      Despite your acknowledgement in response to prior comment 23 that the
         lines aggregated in "All Other Lines" have significantly different
characteristics, please
         tell us why your aggregation of these lines does not obscure useful
information for
         investors. In this regard, tell us the amount of prior period
development for each of the last
         three years for each of the four lines identified in your response. In
addition, given that
         your "All Other Lines" represent almost one-fifth of your incurred
losses in 2018 and
         almost one-fourth of your paid losses in 2018, tell us your
consideration for separately
         presenting your Commercial Multiple Peril line considering the line's
loss expense was
         11.6% of total net losses and loss adjustment expenses incurred during
2018 and 6.9% of
 Joseph J. Beneducci
ProSight Global, Inc.
March 22, 2019
Page 5
      total net reserve for unpaid losses and loss adjustment expenses as of
December 31, 2018.
Notes to Consolidated Financial Statements
18. Segment Information, page F-49

13.   We acknowledge your response to prior comment 26. Please revise your
filing to add
      disclosure of your revenue by product or group of similar products as
required by ASC
      280-10-50-40. In this regard, your "customer segments" appear to be
groupings of classes
      of customers and not groupings of underlying products. It appears that
groupings
      consistent with the product lines presented in your disclosures in Note
13 would be
      appropriate.
       You may contact Sasha Parikh at 202-551-3627 or Mark Brunhofer at
202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Dorrie Yale at 202-551-8776 or Suzanne Hayes at 202-551-3675 with any
other
questions.



                                                          Sincerely,
FirstName LastNameJoseph J. Beneducci
                                                          Division of
Corporation Finance
Comapany NameProSight Global, Inc.
                                                          Office of Healthcare
& Insurance
March 22, 2019 Page 5
cc:       C. Andrew Gerlach
FirstName LastName