January 22, 2020

B. Judd Hartman
General Counsel
PPD, Inc.
929 North Front Street
Wilmington, North Carolina 28401

       Re: PPD, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed January 16, 2020
           File No. 333-235860

Dear Mr. Hartman:

      We have reviewed your amended 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our January 9,
2020 letter.

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

Notes to Condensed Consolidated Financial Statments
Note 4. Goodwill and Intangible Assets, Net
Intangible Assets, Net, page F-85

1.     Please tell us and disclose the estimated aggregate amortization
expenses for each of the
       next five succeeding years. Refer to ASC 350-30-50-2.
Annex A, page A-1

2.     Refer to your proposed "Recent Developments" section beginning on page
A-1 of your
       response letter. We note statements that your actual results "may differ
materially" from
       the estimates you are presenting. In addition, you caution investors
against placing "undue
 B. Judd Hartman
PPD, Inc.
January 22, 2020
Page 2
      reliance" on this information. If you choose to disclose preliminary
results, you should be
      able to assert that the actual results are not expected to differ
materially from that reflected
      in the preliminary results. Accordingly, please remove these statements,
or explain why
      the presentation of this information alongside a disclaimer that the
preliminary financial
      information could differ materially provides meaningful disclosure to
investors.
3.    Refer to the second paragraph on page A-1 of your response letter. Please
tell us why you
      believe presenting revenue and income information for the year ended
December 31, 2019
      without presenting additional financial measures and narrative disclosure
related to your
      costs or gross margin would permit investors to draw appropriate
conclusions regarding
      your financial condition. See Regulation S-K Item 10(b)(2).
4.    We note you intend to disclose the basis point change in Adjusted EBITDA
margin in
      your preliminary financial results overview for the year ended December
31, 2019. Please
      disclose how Adjusted EBITDA margin is determined and how it is used by
management.
      In order to present this Non-GAAP financial measure using a basis point
method, the
      comparable GAAP measure must also be presented and defined. Please refer
to the
      Commission's 2003 Final Rule No. 33-8176, Conditions for Use of Non-GAAP
Financial
      Measures, Section 3(b) on requirements of Regulation G. Please provide
the above
      information or remove the discussion on the change in Adjusted EBITDA
margin.
        You may contact Robert Shapiro at (202) 551-3273 or Jim Allegretto at
(202) 551-3849
if you have questions regarding comments on the financial statements and
related
matters. Please contact Daniel Morris at (202) 551-3314 or Mara Ransom, Office
Chief, at (202)
551-3264 with any other questions.



                                                              Sincerely,
FirstName LastNameB. Judd Hartman
                                                              Division of
Corporation Finance
Comapany NamePPD, Inc.
                                                              Office of Trade &
Services
January 22, 2020 Page 2
cc:       William Brentani, Esq.
FirstName LastName