United States securities and exchange commission logo

                             December 14, 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 October 31, 2022
                                                            Filed November 23,
                                                            File No. 001-38865

       Dear Kelly Steckelberg:

              We have reviewed your December 2, 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
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       October 31, 2022 letter.

       Form 10 for the Quarterly Period Ended October 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Key Business Metrics, page 28

   1.                                                   We note from your
response to prior comment 2 that Entry MRR includes revenue from
                                                        monthly subscribers
that have not provided any indication that they intend to cancel their
                                                        subscriptions. Please
tell us how subscribers who have indicated that they intend to
                                                        cancel their
subscriptions are reflected in your MRR attrition rate calculations. In this
                                                        regard, clarify whether
such customers are included in the attrition rate of the prior
                                                        quarter. If not,
explain how attrition for such customers is captured in your customer
 Kelly Steckelberg
Zoom Video Communications, Inc.
December 14, 2022
Page 2
      churn calculations. Also, revise your disclosures as necessary to clarify
how such
      customers are factored into your calculations.
       You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, 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 Technology
December 14, 2022 Page 2
cc:       Jon Avina
FirstName LastName