February 28, 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. 1 to Draft Registration Statement on Form S-1
           Submitted February 14, 2020
           CIK No. 0001626450

Dear Mr. Bellm:

      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.

       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. 1 to Draft Registration Statement on Form S-1

Prospectus Summary
Our competitive advantages, page 7

1.     You state that the power of your platform to support high growth better
than legacy
       software is evidenced by "the large and growing number of . . . Global
2000 businesses"
       that select you as their ecommerce platform of choice. Please
contextualize this
       disclosure by providing the number or percentage of Global 2000
businesses that are your
       customers as of the end of each period presented.
 Brent Bellm
BigCommerce Holdings, Inc.
February 28, 2020
Page 2
Our Business
Customer case studies, page 94

2.    We note that you provide customer case studies to demonstrate the power
of your
      platform to enhance customers' business performance. For context, please
disclose the
      date (month and year) on which each customer began to use your platform.
Notes to Consolidated Financial Statements
Note 2. Summary of significant accounting policies
Revenue recognition, page F-12

3.    In response to prior comment 16, you indicate on page F-12 that, for your
      solutions, you recognize fixed monthly fees and any overages as revenue
in the month
      earned. Please clarify disclosures elsewhere in your filing indicating
subscription fees are
      recognized ratably to be consistent with this policy in your notes to the
       You may contact Melissa Walsh, Staff Accountant, at (202) 551-6515 or
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
comments on the financial statements and related matters. Please contact
Bernard Nolan,
Attorney-Adviser, at (202) 551-6515 or, in his absence, Kathleen Krebs, Special
Counsel, at
(202) 551-3350 with any other questions.

FirstName LastNameBrent Bellm
                                                            Division of
Corporation Finance
Comapany NameBigCommerce Holdings, Inc.
                                                            Office of
February 28, 2020 Page 2
cc:       Samer M. Zabaneh
FirstName LastName