February 4, 2020

Ramin Sayar
Chief Executive Officer
Sumo Logic, Inc.
305 Main Street
Redwood City, CA 94063

       Re: Sumo Logic, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted January 21, 2020
           CIK: 0001643269

Dear Mr. Sayar:

      We have reviewed your amended draft offering 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 offering statement or publicly filing your offering 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 any amendment to your draft offering statement or filed
offering
statement and the information you provide in response to these comments, we may
have
additional comments. Unless we note otherwise, our references to prior comments
are to
comments in our December 19, 2019 letter.

Draft Registration Statement on Form S-1 Submitted January 21, 2020

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 66

1.     In response to prior comment 5, you indicate that you do not adjust ARR
over the
       subsequent years for the small portion of your contracts that include
increasing fees
       because you believe the initial contract year is the best representation
of a customer's
       commitment upon renewal. Further explain why this is the best
representation and a
       reasonable estimate of the customer's ARR contribution at a certain
point in time. Tell us
       whether customers generally renew at the initial year rate and whether
additional
       disclosure is warranted in this regard. Please also clarify how your
definition of annual
 Ramin Sayar
Sumo Logic, Inc.
February 4, 2020
Page 2
      recurring revenue considers any changes in the contract value upon
renewal.
2.    We note the revisions made to the definition of a customer for purposes
of computing
      ARR and your customer count in response to prior comments 5 and 6.
Further expand
      your disclosure to explain why it is accurate to assume these customers
will renew, and
      consider disclosing your historical renewal rates for each of the periods
presented.
3.    You state that your dollar-based net retention rate was over 120% in each
of the past
      seven quarters. Please provide the actual rates for each period
presented. To the extent
      there are variances between the rates, revise to address any known
underlying material
      trends.
Results of Operations
Comparison of Nine Months Ended October 31, 2018 and 2019, page 74

4.    Please separately quantify the increase in revenue that is attributable
to additional sales to
      existing customers and sales to new customers. Provide an analysis of how
changes in
      revenue correspond to changes in your key business metrics and address
the trend in the
      number of net new customers. Refer to Item 303(a)(3)(iii) and
Instructions to Item 303(a)
      of Regulation S-K.
       You may contact Melissa Walsh, Staff Accountant, at (202) 551-3224 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Matthew Crispino, Staff Attorney, at (202)
551-3456 with any
other questions.



                                                             Sincerely,
FirstName LastNameRamin Sayar
                                                             Division of
Corporation Finance
Comapany NameSumo Logic, Inc.
                                                             Office of
Technology
February 4, 2020 Page 2
cc:       Rezwan Pavri, Esq.
FirstName LastName