December 11, 2018

Jeff Carberry
Chief Financial Officer
Stamps.com Inc.
1990 E. Grand Avenue
El Segundo, California 90245

       Re: Stamps.com Inc
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 28, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Filed November 9, 2018
           File No. 000-26427

Dear Mr. Carberry:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-Q for the Quarterly Period Ended September 30, 2018

Notes to Consolidated Financial Statements
Note 1. Summary of Significant Accounting Policies
Revenue Recognition, page 8

1.    We note your disclosure that service revenues are recognized at a point
in time, as
      transactions are processed, or over a period of time, typically one month
or less. Please
      explain to us and revise your disclosure in future filings to identify
which method applies
      to each of the five ways you list as earning service revenue. See ASC
606-10-50-17.
2.    We note your disclosure in the fourth paragraph that you also provide
mailing and
      shipping services for which the cost of postage or delivery is included
in the cost of the
      service and, therefore, is recognized as service revenue. Please explain
these services in
 Jeff Carberry
Stamps.com Inc.
December 11, 2018
Page 2
         greater detail and whether they are in addition to the five ways you
earn revenues from
         mailing and shipping operations that were outlined in the preceding
paragraph. Please
         clarify your disclosures as necessary in future filings.


3.       Regarding your parcel insurance, we note you recognize the gross
amount charged to the
         customer for purchasing insurance and the related cost represents the
amount paid to your
         insurance providers. Please provide us with your analysis of why it's
appropriate to report
         insurance revenues gross as a principal versus net as an agent. In
doing so, please discuss
         the indicators of gross and net revenue reporting in ASC 605-45-45.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact Scott Stringer, Staff Accountant, at 202-551-3272 or Bill
Thompson,
Accounting Branch Chief, at 202-551-3344 with any questions.



FirstName LastNameJeff Carberry                               Sincerely,
Comapany NameStamps.com Inc.
                                                              Division of
Corporation Finance
December 11, 2018 Page 2                                      Office of
Consumer Products
FirstName LastName