March 31, 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. 2 to Draft Registration Statement on Form S-1
           Submitted March 17, 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
comments. Unless we note otherwise, our references to prior comments are to
comments in
our February 28, 2020 letter.

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

Risk Factors
Risks related to our business and industry
Our current operations are international in scope . . ., page 36

1.     You refer to the novel Coronavirus outbreak as a risk that may impact
your current
       international operations and future initiatives. We note, however, that
the outbreak may
       have an impact on not only your international operations but also your
       operations. To the extent material, please expand upon your disclosure
by providing a
       separately captioned risk factor addressing the known or reasonably
likely effects of and
 Brent Bellm
FirstName LastNameBrent Bellm
BigCommerce Holdings, Inc.
March 31, NameBigCommerce Holdings, Inc.
March 31, 2020 Page 2
Page 2
FirstName LastName
         the types of risks presented by the outbreak, as well as how you are
responding to them.
         For example, as it appears that the outbreak is materially impacting,
or is expected to
         materially impact, retail spending and, by extension, the sales of
your domestic and
         international customers, please discuss the known or reasonably likely
effects of the
         outbreak on your financial condition and results of operations. In
this regard, we note that
         as your customers generate more online sales, you generate more
subscription revenue
         through automated sales-based upgrades on your Essentials plans and
order adjustments
         on your Enterprise plans. For guidance, refer to CF Disclosure
Guidance: Topic No. 9.
Management's Discussion and Analysis of Financial Condition and Results of
Liquidity and Capital Resources, page 73

2.       You state in Note 1 to the fiscal year 2019 financial statements that
the $35.0 million
         convertible term loan has alleviated your substantial doubt as to your
ability to continue as
         a going concern and that, based upon your current operating plan, you
believe you have
         sufficient resources to fund operations through the second quarter of
2021. Please
         reconcile this statement with your statement on page 73 that you
believe the net proceeds
         from this offering will be sufficient to meet your working capital and
capital expenditure
         needs and debt service obligations for at least the next 12 months.
Critical accounting policies and estimates, page 76

3.       We note the disclosure added to pages 66 and 76 in response to prior
comment 3
         indicating that fixed monthly fees and any overage charges related to
         solutions are recognized as revenue in the month they are earned. Tell
us why you
         continue to also disclose that subscription revenue is recognized
Audited Consolidated Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2

4.       The references to your financial statements should be collectively
defined and consistently
         referred to throughout the audit report. Please revise accordingly.
Notes to Consolidated Financial Statements
Note 10. Income taxes, page F-25

5.       Please accurately reconcile your effective tax rate for the year ended
December 31, 2019.
Note 11. Net loss and unaudited pro forma net loss per share, page F-28

6.       Please confirm that you will give effect to the number of shares whose
proceeds from the
         offering will be used to pay the Series F Dividend in your computation
of pro forma net
         loss per share. Refer to SAB Topic 1.B.3.
 Brent Bellm
BigCommerce Holdings, Inc.
March 31, 2020
Page 3

       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
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 Technology
March 31, 2020 Page 3
cc:       Samer M. Zabaneh
FirstName LastName