March 13, 2019

Eric S. Yuan
President and Chief Executive Officer
Zoom Video Communications, Inc.
55 Almaden Boulevard, 6th Floor
San Jose, California 95113

       Re: Zoom Video Communications, Inc.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted March 7, 2019
           CIK No. 0001585521

Dear Mr. Yuan:

       We have reviewed your amended draft registration statement and have the
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure. References to prior comments refer to
our February 28,
2019 letter.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional

Amendment No. 2 to Draft Registration Statement on Form S-1

Prospectus Summary, page 3

1.     In response to prior comment 1, you state that you include monthly
subscriptions in
       MRR due to historically low cancellation rates as reflected in your net
dollar expansion
       rate. Please explain how low cancellation rates are reflected in this
measure. In this
       regard, net dollar based expansion rate is calculated using the same set
of customers from
       one period to the next, which would not appear to contemplate attrition.
To help us better
       understand your basis for including monthly subscription revenue in MRR,
please provide
       us with cancellation/attrition rates or, alternatively, renewal rates
for your monthly
       subscribers for the periods presented.
 Eric S. Yuan
Zoom Video Communications, Inc.
March 13, 2019
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Overview, page 55

2.     You state that you have seen an increase in the proportion of annual and
       subscriptions and billings. Please tell us and revise to disclose the
portion of revenue
       generated from monthly vs. annual and multi-year subscriptions for each
       presented. To the extent a substantial portion of your revenues are from
       subscriptions, please tell us what measures are used to monitor your
ability to retain and
       grow your monthly subscriber base. Refer to Item 303(a)(3) of Regulation
S-K and
       Section III.B.1 of SEC Release No. 33-8350.
Key Factors Affecting Our Performance, page 57

3.     Please revise your discussion of net dollar base expansion rate to
explain why you are
       presenting this measure for only the most recent three quarters as you
have indicated in
       your response to prior comment 4.
Key Business Metrics, page 58

4.     Your two key business metrics are presented as a percentage of total
annual recurring
       revenue (ARR), which you define as the annualized revenue run-rate of a
       customer agreement at a point in time. Please disclose the total ARR for
each period
       presented. Also, tell us the amount and percentage of revenue for each
period presented
       attributable to both Customers with Greater than 10 Employees and
Customers with
       Greater than $100,000 of Annual Recurring Revenue. To the extent revenue
       to these groups differs materially from ARR, please revise to provide a
       discussion of both revenue and ARR measures for each.
        You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters. Please contact Mitchell Austin, Staff
Attorney, at (202)
551-3574 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other


FirstName LastNameEric S. Yuan                               Division of
Corporation Finance
                                                             Office of
Information Technologies
Comapany NameZoom Video Communications, Inc.
                                                             and Services
March 13, 2019 Page 2
cc:       Alex K. Kassai, Esq.
FirstName LastName