April 22, 2020

Mark Partin
Chief Financial Officer
Blackline, Inc.
21300 Victory Boulevard, 12th Floor
Woodland Hills, CA 91367

       Re: Blackline, Inc.
           Form 10-K for the Year Ended December 31, 2019
           Filed February 27, 2020
           File No. 001-37924

Dear Mr. Partin:

       We have reviewed your filing and have the following comment. In our
comment, we ask
you to provide us with information so we may better understand your disclosure.

       Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2019

Note 11. Income Taxes , page 84

1.    Please provide additional context disclosing why the decrease in the tax
valuation
      allowance was recorded through equity and advise us. Explain to us the
nature of this
      adjustment and your basis for recording it under GAAP. Also tell us how
you recorded
      the adjustment in your financial statements and why it does not appear on
your
      Consolidated Statements of Stockholders' Equity.
 Mark Partin
Blackline, Inc.
April 22, 2020
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or
Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have
questions regarding
comments on the financial statements and related matters.



FirstName LastNameMark Partin                             Sincerely,
Comapany NameBlackline, Inc.
                                                          Division of
Corporation Finance
April 22, 2020 Page 2                                     Office of Technology
FirstName LastName