January 22, 2020

Craig Courtemanche
President and Chief Executive Officer
Procore Technologies, Inc.
6309 Carpinteria Avenue
Carpinteria, California 93013

       Re: Procore Technologies, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted January 13, 2020
           CIK No. 0001611052

Dear Mr. Courtemanche:

      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
December 17, 2019 letter.

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

Prospectus Summary, page 1

1.     Please tell us how you determine and define the various user metrics
disclosed such as (a)
       the 1.3 million users of your platform; (b) 60% of users that were
collaborators; and
       (c) 170 users on average per customer. In this regard, your response to
prior comment 7
       indicates that you are unable to accurately determine which
collaborators become
       customers since collaborators use a variety of different log-in
credentials and devices to
       access your platform. Also, given your inability to track the conversion
of collaborators
       to users, please further explain your assertions that once collaborators
have used your
       platform, they may potentially become customers and evangelize your
products.
 Craig Courtemanche
Procore Technologies, Inc.
January 22, 2020
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 58

2.    On page 5, you refer to "only 41%" of your customers subscribing to four
or more of your
      products as a means to illustrate potential future market expansion. You
further explain
      that several of your products are new and you believe your market
opportunity could
      expand as you introduce new products. However, you state here that 59% of
your
      customers subscribed to three or more of your products, which you believe
illustrates
      successful introduction of new products. Please clarify these
disclosures, as these
      statements appear to be somewhat inconsistent.
        You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters. Please contact Bernard Nolan,
Attorney-Adviser, at
(202) 551-6515 or, in his absence, Larry Spirgel, Office Chief, at (202)
551-3815 with any other
questions.



                                                           Sincerely,
FirstName LastNameCraig Courtemanche
                                                           Division of
Corporation Finance
Comapany NameProcore Technologies, Inc.
                                                           Office of Technology
January 22, 2020 Page 2
cc:       Peter N. Mandel
FirstName LastName