Qualtrics International Inc.

333 West River Park Drive

Provo, Utah 84604

January 25, 2021

Via EDGAR

Securities and Exchange Commission

Office of Technology

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn: Edwin Kim, Stephen Krikorian, Ryan Rohn and Jan Woo

RE:    Qualtrics International Inc.

Registration Statement on Form S-1

File No. 333-251767

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Qualtrics International Inc. (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will be declared effective under the Securities Act at 4:00 p.m. Eastern Time on January 27, 2021, or as soon thereafter as is practicable, or such other time as the Company or its outside counsel, Shearman & Sterling LLP, may request by telephone that such Registration Statement be declared effective.

We request that we be notified of such effectiveness by a telephone call to Richard Alsop of Shearman & Sterling LLP at (212) 848-7333 and that such effectiveness also be confirmed in writing.

Very truly yours,
Qualtrics International Inc.
	/s/ Zig Serafin
By:	Zig Serafin
Title:	Chief Executive Officer

cc:    Blake Tierney, General Counsel, Qualtrics International Inc.

Mary Beth Hanss, Senior Vice-President and General Counsel, SAP America, Inc.

Daniel Mitz, Shearman & Sterling LLP

Lona Nallengara, Shearman & Sterling LLP

Richard Alsop, Shearman & Sterling LLP

Kristina Trauger, Shearman & Sterling LLP

Anthony J. McCusker, Goodwin Procter LLP

Bradley C. Weber, Goodwin Procter LLP