March 6, 2020 David Barter Chief Financial Officer Model N, Inc. 777 Mariners Island Boulevard, Suite 300 San Mateo, California 94404 Re: Model N, Inc. Form 10-K for the Fiscal Year Ended September 30, 2019 Filed November 15, 2019 File No. 001-35840 Dear Mr. Barter: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology