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                              February 23, 2024

       John Rettig
       Chief Financial Officer
       Bill Holdings, Inc.
       6220 America Center Drive, Suite 100
       San Jose, CA 95002

                                                        Re: Bill Holdings, Inc.
                                                            Form 10-K for the
fiscal year ended June 30, 2023
                                                            Form 8-K furnished
on August 17, 2023
                                                            Response dated
February 16, 2024
                                                            File No. 001-39149

       Dear John Rettig:

              We have reviewed your February 16, 2024 response to our comment
letter and have the
       following comments.

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

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our January 19, 2024
       letter.

       Form 10-K for the fiscal year ended June 30, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       Comparison of Fiscal 2023 and 2022, page 65

   1.                                                   We note your response
to prior comment 2. Please separately disclose the amount of
                                                        subscription revenue
versus transaction revenue in your MD&A. In this regard, your
                                                        response indicates that
you believe this information is useful to investors and provides
                                                        insight into management
  s perspective on the company   s business performance.
 John Rettig
FirstName  LastNameJohn Rettig
Bill Holdings, Inc.
Comapany23,
February   NameBill
             2024 Holdings, Inc.
February
Page  2 23, 2024 Page 2
FirstName LastName
Form 8-K furnished on August 17, 2023
Exhibit 99.1
Reconciliation of net loss, page 13

2.       We note your response to prior comment 4. Please revise to include a
separate income tax
         adjustment commensurate with your non-GAAP measure of profit beginning
with your
         next fiscal quarter and ensure that all prior periods are revised
accordingly. Also, refrain
         from presenting "Current method of non-GAAP net income" as proposed in
your
         response. Refer to Non-GAAP C&DI Question 102.11.
       Please contact Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 if you
have questions regarding comments on the financial statements and related
matters.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Raj Aji