July 12, 2018

Alexander J. Lurie
Chief Executive Officer
SVMK Inc.
One Curiosity Way
San Mateo, CA 94403

       Re: SVMK Inc.
           Draft Registration Statement on Form S-1
           Submitted June 15, 2018
           CIK No. 0001739936

Dear Mr. Lurie:

       We have reviewed your 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.

Draft Registration Statement on Form S-1 Submitted June 15, 2018

Prospectus Summary
Overview, page 1

1.     You state that you have attracted an aggregate of approximately 58
million registered
       users since your founding. Please clarify whether this figure includes
inactive registered
       users.
2.     You refer to 15 million active users and more than 200,000
organizational domains
       throughout the filing. Please revise to explain how you define each of
these measures.
       Disclose the number of active users, organizational domains, and paying
users for each
 Alexander J. Lurie
FirstName LastNameAlexander J. Lurie
SVMK Inc.
Comapany NameSVMK Inc.
July 12, 2018
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FirstName LastName
         period presented to provide further context to these measures. If
available, please provide
         more granular information such as quarterly or monthly activity for
active users as
         opposed to activity "within the past year."
3.       Clarify the extent to which you have a presence in the "99% of the
Fortune 500"
         companies in which you have paying users. In addition, explain the
statement on your
         website that you are "[t]rusted by 40 million customers around the
world."
The Offering, page 11

4.       Please tell us why the 3,065,172 of performance-based RSUs that will
vest upon
         effectiveness of the offering are not included in the number of shares
outstanding after the
         offering, or revise.
Summary Consolidated Financial and Other Data
Non-GAAP Financial Measures, page 15

5.       Please disclose the corresponding GAAP measure related to free cash
flow with equal or
         greater prominence both here and on page 63. Refer to Item
10(e)(1)(i)(A) of Regulation
         S-K and Question 102.10 of the Non-GAAP Compliance and Disclosure
Interpretations.
         Also, you state on page 71 that free cash flow is important because it
measures the amount
         of cash you spend or generate and reflects changes in your working
capital. As this
         information would be captured in your GAAP measure of cash flows from
         operations, please revise to clarify how free cash flow provides
useful information to
         investors. Refer to Item 10(e)(1)(i)(C) of Regulation S-K.
6.       Please revise the title of your non-GAAP measure, product revenue, so
that it is not
         confusingly similar to titles or descriptions used for GAAP financial
measures. Refer to
         Item 10(e)(1)(ii)(E) of Regulation S-K.
7.       We note that the calculation of average revenue per user (ARPU) is
based on product
         revenue, a non-GAAP measure. Please revise to identify this as a
non-GAAP measure
         and provide the applicable disclosures as required by Item 10(e)(1)(i)
of Regulation S-K.
         Also, clarify whether ARPU includes users of the non-self-serve
portion of
         SurveyMonkey Audience.
Risk Factors
Our debt service requirements and restrictive covenants limit our ability . .
.., page 46

8.       Please revise to address the risks associated with the fact that your
existing credit facility
         is guaranteed by certain of your subsidiaries and secured by liens on
substantially all your
         assets and such subsidiaries.
 Alexander J. Lurie
FirstName LastNameAlexander J. Lurie
SVMK Inc.
Comapany NameSVMK Inc.
July 12, 2018
July 12, 2018 Page 3
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FirstName LastName
Selected Consolidated Financial and Other Data
Key Business Metrics, page 62

9.       In your risk factor disclosure on page 17, you indicate that you do
not track the retention
         rates of your individual active users. However, we note your
disclosure on page 68,
         which states that over 75% of your revenue was from individuals and
organizations that
         were customers in 2016. Please tell us whether you monitor retention
of paying users,
         organizational domains or revenue. If so, revise to disclose any
retention metrics used for
         each period presented. Refer to Item 303(a)(3) of Regulation S-K and
Section III.B.1 of
         SEC Release No. 33-8350.
10.      You state that your growth strategy is focused on converting unpaid
users to paying users,
         upselling organizations to SurveyMonkey Enterprise plans, and
cross-selling purpose-built
         solutions to organizations. Please revise to explain how you measure
the extent to which
         you convert free users to paid users, upsell to Enterprise plans, or
cross-sell purpose-built
         solutions and describe any known material trends in such measures.
11.      You state on page 17 that the actual number of unique paying users is
lower than you
         report. Please revise to clarify whether your other user metrics, such
as registered and
         active users, may also count single users multiple times. Also, tell
us whether you are
         able to monitor the extent to which your users are counted more than
once and, if so,
         provide us with the actual number of unique users for each period
presented.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 65

12.      Please tell us and disclose the amount of revenue related to
Enterprise plans and the
         number of Enterprise plan customers or organizations for each period
presented. Refer to
         Item 303(a)(3) of Regulation S-K and Section III.B.1 of SEC Release
No. 33-8350.
13.      Please address any known trends or uncertainties related to your focus
on upselling
         organizations to the Enterprise subscription plan, expanding
deployments, and cross-
         selling organizational users to purpose-built solutions. Specifically
address the impact on
         revenue, cost of revenue, operating expenses, and ARPU as you pursue
this sales
         strategy. In this regard, we note your disclosure on page 17 that you
may encounter
         greater pricing pressure and longer and more expensive sales cycles
for Enterprise
         customers.
14.      We note that some of your pre-existing plans appear to provide
advanced team-based
         features. Please explain how and the extent to which your customers
have historically
         used team-based capabilities within your Advantage and Premier
subscription
         plans. Disclose any risks and challenges that you anticipate with
regard to upselling such
         customers to your Enterprise plan.
 Alexander J. Lurie
FirstName LastNameAlexander J. Lurie
SVMK Inc.
Comapany NameSVMK Inc.
July 12, 2018
July 12, 2018 Page 4
Page 4
FirstName LastName
Comparison of the Years Ended December 31, 2016 and 2017
Revenue and Cost of Revenues, page 80

15.      You disclose that revenues increased primarily due to an increase in
ARPU as well as an
         increase in the number of paying users. Please separately quantify the
impact on revenues
         attributable to the increase in ARPU and the increase in paying users.
Similar revisions
         should be made to your interim results of operations discussion. Refer
to Item
         303(a)(3)(ii) of Regulation S-K and Section III.D of SEC Release No.
33-6835.
16.      Please separately quantify the impact on revenues attributable to
existing customers and
         new customers for each period presented, or explain why you do not
believe this
         information is important to investors given your focus on converting
unpaid users and
         upselling existing paid users.
17.      You state that the increase in ARPU was largely driven by a change to
your individual
         user plans in 2017 that offered paying users new plans with more
functionality at higher
         price points. Please clarify whether customers were required to renew
their subscriptions
         at higher price points. If so, revise to discuss any known material
trends and uncertainties
         that may impact your revenues should similar prices increases not
occur in the future.
Internal Control Over Financial Reporting, page 89

18.      You state that you have addressed the material weakness in your
internal control over
         financial reporting by enhancing the expertise of your finance and
accounting staff and
         updating your accounting policy. Please clarify whether you believe
the material
         weakness has been remediated. To the extent you continue to address
this weakness,
         please include a discussion of any additional remediation plans,
including the costs
         necessary to implement such plans, if material.
Certain Relationships and Related Party Transactions
Fourth Amended and Restated Stockholders Agreement, as Amended, page 137

19.      Please identify the holders of your capital stock as well as the
directors who are affiliated
         with such holders pursuant to Item 404(a)(1) of Regulation S-K.
Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition and Deferred Revenue, page F-10

20.      Please revise to include the amount of revenue recognized in each year
presented that was
         included in deferred revenue as of the beginning of each respective
period. Refer to ASC
         606-10-50-8.
21.      We note that you generate revenue from a wide range of purpose-built
solutions. Please
         tell us the nature of the purpose-built subscription services and the
timeframe over which
 Alexander J. Lurie
FirstName LastNameAlexander J. Lurie
SVMK Inc.
Comapany NameSVMK Inc.
July 12, 2018
July 12, 2018 Page 5
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FirstName LastName
         they are provided. Clarify whether these subscriptions are considered
separate
         performance obligations from the subscriptions to the survey platform.
If accounted for
         separately, tell us when revenue is recognized. Refer to ASC
606-10-25-19 and 25-23 and
         ASC 606-10-50-12.
Concentration of Credit Risk, page F-14

22.      We note that you treat multiple users within a single organization as
separate paying users
         for your key metrics disclosures. Please revise to define a customer
for purposes of your
         concentration of credit risk disclosure. Refer to ASC 280-10-50-42.
Note 7. Mandatorily Redeemable Convertible Preferred Stock, Stockholders'
Equity and
Employee Benefit Plans
Fair Value of Stock Options, page F-26

23.      Please revise to provide the weighted average estimated fair value or
a range of the
         estimated per share value of the underlying common stock used to
determine the fair value
         of your stock option grants. Refer to ASC 718-10-50-2(f)(2).
Note 14. Subsequent Events, page F-38

24.      Please provide us with a breakdown of all stock-based compensation
awards granted
         during fiscal 2017 and to date in 2018 and include the fair value of
the underlying
         common stock used to value such awards at each grant date. To the
extent there were any
         significant fluctuations in the fair values from period-to-period,
describe for us the factors
         that contributed to these fluctuations, including any intervening
events within the
         company or changes in your valuation assumptions or methodology. Also,
please disclose
         any stock-based compensation awards granted subsequent to March 31,
2018, including
         the expected financial statement impact, if material. Refer to ASC
855-10-45-4.
General

25.      We note that your prospectus includes graphical materials and artwork.
Please
         supplementally provide us with copies of any additional graphical
materials or artwork
         that you intend to use in your prospectus. Upon review of such
materials, we may have
         further comments. For guidance, consider Question 101.02 of our
Securities Act Forms
         Compliance and Disclosure Interpretations.
26.      Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
         not they retain copies of the communications.
 Alexander J. Lurie
SVMK Inc.
July 12, 2018
Page 6

       You may contact Joyce Sweeney, Senior Staff Accountant, at (202)
551-3449 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 at if you have
questions
regarding comments on the financial statements and related matters. Please
contact Bernard
Nolan, Staff Attorney, at (202) 551-6515 or Jan Woo, Legal Branch Chief, at
(202) 551-
3453 with any other questions.



FirstName LastNameAlexander J. Lurie                      Division of
Corporation Finance
                                                          Office of Information
Technologies
Comapany NameSVMK Inc.
                                                          and Services
July 12, 2018 Page 6
cc:       Rezwan D. Pavri
FirstName LastName