August 5, 2024

James C. Malone
Chief Financial Officer
Consensus Cloud Solutions, Inc.
700 S. Flower Street, 15th Floor
Los Angeles, California 90017

       Re: Consensus Cloud Solutions, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 8-K furnished May 8, 2024
           File No. 001-40750
Dear James C. Malone:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Key Performance Metrics, page 39

1.     We note from your disclosures in footnote (4) monthly churn is defined
as paying
       customer accounts that cancelled services during the period divided by
the average
       number of customers over the period. Please tell us how you determine
the "average
       number of customers over the period," and explain why you do not divide
lost customers
       by the number of customer at the beginning of the month in calculating
monthly churn.
Notes to Consolidated Financial Statements
Note 3. Revenues, page 65

2.     Please tell us the amount of revenue derived from usage-based
arrangements for each
       period presented and what consideration you have given to disclosing how
revenue is
       recognized for such arrangements. We refer you to comment 23 in your
July 23, 2021
       response letter. Refer to ASC 606-10-50-18(a).
 August 5, 2024
Page 2

Form 8-K furnished May 8, 2024
Exhibit 99.1, page 1

3.     You discuss the non-GAAP measures EBITDA margin. free cash flow and net
debt-to-
       EBITDA ratio in the opening paragraph without providing a discussion of
the most
       directly comparable GAAP measures. You also discuss adjusted EBITDA
margin in the
       highlights section without discussing the comparable GAAP measure of net
income
       margin. Please revise to discuss the most directly comparable GAAP
measures with equal
       or greater prominence. In addition, clarify whether the reference to
"EBITDA" in the
       opening remarks is to adjusted EBITDA. Lastly, describe how you
calculate your net
       debt-to-EBITDA ratio. Refer to Item 10(e)(1)(i) (A) of Regulation S-K
and Question
       102.10(a) of the non-GAAP C&DIs.
Reconciliation of GAAP to Adjusted Non-GAAP Financial Measures, page 8

4.     We note that Adjusted non-GAAP net income contains adjustments presented
on an after-
       tax basis. Please revise to present such adjustments on a pre-tax basis
and include a
       separate line-item in the reconciliation for the income tax impact on
such adjustments.
       Refer to Question 102.11 of the non-GAAP C&DIs.
       In closing, 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.

       Please contact Dave Edgar at 202-551-3459 or Kathleen Collins at
202-551-3499 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:   Vithya Aubee