July 27, 2018

Kevin Thompson
Chief Executive Officer
SolarWinds Corporation
7171 Southwest Parkway, Building 400
Austin, TX 78735

       Re: SolarWinds Corporation
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted July 10, 2018
           CIK 0001739942

Dear Mr. Thompson:

      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 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
June 28, 2018 letter.

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

Market Opportunity, page 3

1.     We note your response to prior comment 3. Please provide additional
details regarding
       the commissioning of the Compass Intelligence report in April 2018 with
a particular
       focus on why it should not be considered having been prepared "in
connection with" your
       registration statement.
 Kevin Thompson
SolarWinds Corporation
July 27, 2018
Page 2
Business, page 97

2.       We note your response to prior comment 8. To provide additional
context to this metric,
         please provide the smallest or a range of amounts a customer can
purchase. Clarify that
         the increase in customers is being provided in order to highlight your
"go-to-market
         approach" as indicated in your response.
       You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Barbara Jacobs, Assistant Director, at (202)
551-3735 with any
other questions.


FirstName LastNameKevin Thompson
                                                             Division of
Corporation Finance
Comapany NameSolarWinds Corporation
                                                             Office of
Information Technologies
July 27, 2018 Page 2                                         and Services
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