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                             October 21, 2020

       Alexander Timm
       Chief Executive Officer
       Root, Inc.
       80 E. Rich Street, Suite 500
       Columbus, Ohio 43215

                                                        Re: Root, Inc.
                                                            Amendment No. 1 to
                                                            Registration
Statement on Form S-1
                                                            Filed October 20,
2020
                                                            File No. 333-249332

       Dear Mr. Timm:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 registration 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
October 14, 2020 letter.

       Amendment No. 1 to Form S-1 filed October 20, 2020

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operation
       Certain Quarterly Information, page 91

   1.                                                   We note your response
to prior comment 1 regarding your Ratio of Renewal to Direct
                                                        Earned Premium. Please
revise your disclosure to address the following:
                                                            We note your
revised disclosure that provides a definition of this ratio. Further revise
                                                            your definition to
specifically disclose the following:
                                                              o  As previously
requested revise to disclose why you believe this ratio to be a
                                                                 meaningful
metric to your investors.
 Alexander Timm
Root, Inc.
October 21, 2020
Page 2
                 o Clarify what renewal premiums are included in the numerator
of this ratio. In
                   this regard, it is unclear whether direct or net premiums
are included and
                   whether earned or written premiums are included.
                We also note your inclusion of the two new ratios under Direct
Accident Period Loss
              Ratio in this table. Revise your disclosure to provide the
definitions for each and
              disclose why these ratios are meaningful to your investors. In
your revised disclosure
              ensure that you clearly indicate the composition of both the
numerator and
              denominator of these ratios.
Notes to Condensed Consolidated Financial Statements
Subsequent Events, page F-55

2.       In your October 15, 2020 correspondence you indicate your expectation
that your board of
         directors will act to grant additional equity awards during the week
of October 12,
         2020, with the exercise price of any options so granted equal to the
initial public offering
         price, and to be effective when the Registration Statement becomes
effective. You further
         stated these awards would be disclosed in your preliminary prospectus.
As your
         subsequent event footnote is silent and your Item 15 disclosures on
page II-1 have not
         changed from your original filing for any such grants, please tell us
whether these grants
         have been made and, if so, why you do not appear to disclose them.
Otherwise, tell us
         where you have made such disclosure or why such disclosure is not
warranted.
       You may contact Bonnie Baynes at 202-551-4924 or Mark Brunhofer at
202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please
contact John Stickel at 202-551-3324 or Justin Dobbie at 202-551-3469 with any
other questions.



FirstName LastNameAlexander Timm                               Sincerely,
Comapany NameRoot, Inc.
                                                               Division of
Corporation Finance
October 21, 2020 Page 2                                        Office of
Finance
FirstName LastName