United States securities and exchange commission logo

                            July 9, 2020

       Brent Bellm
       President and Chief Executive Officer
       BigCommerce Holdings, Inc.
       11305 Four Points Drive
       Building II, Third Floor
       Austin, TX 78726

                                                        Re: BigCommerce
Holdings, Inc.
                                                            Amendment No. 3 to
Draft Registration Statement on Form S-1
                                                            Submitted June 29,
                                                            CIK No. 0001626450

       Dear Mr. Bellm:

             We have reviewed your amended draft registration statement 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 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

             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. 3 to Draft Registration Statement on Form S-1

       Management   s Discussion and Analysis of Financial Condition and
Results of Operations
       Overview, page 67

   1.                                                   Please revise to
quantify the changes and trends in revenue associated with the COVID-19
                                                        pandemic. In this
regard, disclose the amount that partner and services revenue increased
                                                        due to higher ecommerce
activity in connection with the COVID-19 pandemic separately
                                                        from the increase
attributable to improved monetization of partner service revenue. In
                                                        addition, provide an
indication of how much Enterprise plan sales decreased in March, as
                                                        well as the amount of
the improvement in April and May. Also quantify the significant
                                                        increases in Essentials
plan sales in March, April, and May.
 Brent Bellm
BigCommerce Holdings, Inc.
July 9, 2020
Page 2
Key business metrics, page 71

2.     Please update to provide your net revenue retention rate as of March 31,
Critical accounting policies and estimates
Grants of share-based awards, page 90

3.     Please revise to reconcile the number of shares of common stock subject
to options and
       restricted stock units granted since January 1, 2019 to the disclosures
in your financial
       statements. Also, ensure that your subsequent events disclosure
addresses the restricted
       stock units granted after the balance sheet date, including disclosure
of an estimate of the
       financial effect, in accordance with ASC 855-10-50-2.
Notes to Consolidated Financial Statements, page F-8

4.     Please revise to explain the adjustments to be assumed in your pro forma
balance sheet as
       of March 31, 2020.
       You may contact Melissa Walsh, Staff Accountant, at (202) 551-3224 or
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
comments on the financial statements and related matters. Please contact
Kathleen Krebs,
Special Counsel, at (202) 551-3350 or Jan Woo, Legal Branch Chief, at (202)
551-3453 with any
other questions.

FirstName LastNameBrent Bellm
                                                              Division of
Corporation Finance
Comapany NameBigCommerce Holdings, Inc.
                                                              Office of
July 9, 2020 Page 2
cc:       Samer M. Zabaneh
FirstName LastName