September 9, 2024

Kathryn Bailey
Chief Financial Officer
Peoples Bancorp Inc.
138 Putnam Street, PO Box 738
Marietta, OH 45750

       Re: Peoples Bancorp Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           File No. 000-16772
Dear Kathryn Bailey:

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

       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 Fiscal Year Ended December 31, 2023
Item 7 Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 48

1.     We note your disclosure on page 58 of "pre-provision net revenue per
common share
       diluted" and    pre-provision net revenue to total average assets.    We
also note that these
       measures are presented in certain of your current reports, such as your
news release
       included in Form 8-K on July 23, 2024. Please tell us how you determined
that these
       measures do not represent individually tailored accounting measures.
Refer to Question
       100.04 of the Division of Corporation Finance   s Compliance &
Disclosure Interpretations
       on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
       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.
 September 9, 2024
Page 2

       Please contact Katharine Garrett at 202-551-2332 or John Nolan at
202-551-3492 with
any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Finance