June 11, 2019

Davinder Athwal
Chief Financial Officer
Blucora, Inc.
6333 State Hwy 161
4th Floor
Irving, TX 75038

       Re: Blucora, Inc.
           Form 10-Q for the Quarterly Period Ended March 31, 2019
           Filed May 8, 2019
           File No. 000-25131

Dear Mr. Athwal:

       We have reviewed your filing 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 Quarter Ended March 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Segment Revenue / Operating Income
Wealth Management
Advisory revenue, page 20

1.    We note your rollforward of advisory assets on page 20, along with your
related
      discussion of changes in advisory revenues on page 21. Please address and
revise your
      future disclosure for the items below.

          Provide a "gross" presentation of net increase (decrease) of new
advisory asset flows
          (i.e., separately quantify gross inflows and outflows, rather than
only a net change).
 Davinder Athwal
Blucora, Inc.
June 11, 2019
Page 2
             Clarify whether there is any material impact from foreign currency
exchange
             adjustments, acquisitions or dispositions during any period
presented and if so,
             disclose them separately and explain what they are.

             Provide additional details of the activities of your advisory
assets by investment focus,
             fund type, asset class, client type or other category, as
examples, in order to provide
             investor's with enough information to understand the composition
of your advisory
             assets. If this is not possible, tell us why.

             Disclose your weighted average fee rates by respective category
above for each period
             presented, along with a related discussion of trends and how those
changes in the
             weighted average fee rates impact your advisory revenues.
        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 Cara Lubit, Staff Accountant, at 202-551-5909 or Robert
Klein, Staff
Accountant, at 202-551-3847 with any questions.



FirstName LastNameDavinder Athwal                               Sincerely,
Comapany NameBlucora, Inc.
                                                                Division of
Corporation Finance
June 11, 2019 Page 2                                            Office of
Financial Services
FirstName LastName