United States securities and exchange commission logo

                             October 31, 2022

       Kelly Steckelberg
       Chief Financial Officer
       Zoom Video Communications, Inc.
       55 Almaden Boulevard
       6th Floor
       San Jose, CA 95113

                                                        Re: Zoom Video
Communications, Inc.
                                                            Form 10-K for the
Fiscal Year Ended January 31, 2022
                                                            Filed March 7, 2022
                                                            Form 10-Q for the
Quarterly Period Ended July 31, 2022
                                                            Filed August 24,
                                                            File No. 001-38865

       Dear Kelly Steckelberg:

              We have reviewed your October 19, 2022 response to our comment
letter 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional comments.
       Unless we note otherwise, our references to prior comments are to
comments in our September
       28, 2022 letter.

       Form 10-Q for the Quarterly Period Ended July 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Key Business Metrics, page 27

   1.                                                   We note from your
response to prior comment 5 that you refer to those customers that are
                                                        not Enterprise
customers as Online customers and you use similar references in your
                                                        earnings call
transcripts. Please revise future filings to include a discussion of this
                                                        customer base and
explain how you define an "Online customer." You also state that you
                                                        do not have visibility
into whether a single individual signs up for multiple Zoom
                                                        accounts under
different e-mail addresses and therefore, you do not intend to disclose the
 Kelly Steckelberg
Zoom Video Communications, Inc.
October 31, 2022
Page 2
      number of Online customers. Please explain why you cannot disclose the
number of
      Online subscriptions with an explanation that certain accounts may be
held by the same
2.    We also not that you intend to disclose average monthly recurring revenue
      attrition rates for your Online customers. Please tell us what this rate
represents and how
      it is calculated. Also tell us the percentage of Online customer revenue
from monthly,
      annual or multi-year subscriptions and explain how each is factored into
the attrition rate
      you intend to disclose.
Non-GAAP Financial Measures
Free Cash Flow and Adjusted Free Cash Flow, page 47

3.    You state in your response to prior comment 4 that your presentation of
adjusted free cash
      flow does not violate the prohibitions in Item 10(e)(1)(ii)(A) of
Regulation S-K.
      However, this guidance specifically indicates that the exclusion of
charges or liabilities
      that required, or will require, cash settlement, or would have required
cash settlement
      absent an ability to settle in another manner, cannot be excluded from
      liquidity measures other than EBIT and EBITDA. As such, please revise to
remove this
       You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.

FirstName LastNameKelly Steckelberg
                                                            Division of
Corporation Finance
Comapany NameZoom Video Communications, Inc.
                                                            Office of
October 31, 2022 Page 2
cc:       Jon Avina
FirstName LastName