December 26, 2018

Anthony Wood
Chief Executive Officer
Roku, Inc.
150 Winchester Circle
Los Gatos, CA 95032

       Re: Roku, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           Form 10-Q for the Quarterly Period Ended September 30, 2018
           Filed November 9, 2018
           File No. 001-38211

Dear Mr. Wood:

        We have reviewed your filings and have the following comments. Please
comply with
the following comments in future filings. Confirm in writing that you will do
so and explain to
us how you intend to comply. 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 Unaudited Condensed Consolidated Financial Statements
12. Revenue, page 17

1.     Your MD&A disclosures on pages 28 and 29 as well as statements made in
your earnings
       releases suggest that quantitative information about revenue by nature
of service (such as
       advertising, licensing, subscription) may be both presented outside of
the financial
       statements and used by investors and analysts to evaluate your financial
performance. For
       example, in the shareholder letter filed as an exhibit to your November
7, 2018 Form 8-K,
       you indicated that nearly two-thirds of the increase in platform revenue
for the three
       months ended September 30, 2018 was due to "advertising services such as
video ads,
       audience development and brand sponsorship advertising on the Roku user
interface."
 Anthony Wood
Roku, Inc.
December 26, 2018
Page 2
         Please tell us how you considered providing disaggregated revenue
disclosures by type of
         service. Please refer to ASC 606-10-55-89 through 55-91.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
24

2.       As disclosed in your shareholder letter dated November 7, 2018, we
note that the Roku
         Channel has become a material source of ad impressions and
monetization on your
         platform. In future filings, with respect to your average revenue per
user and platform
         revenue growth, please expand your disclosure to address what portion
of that growth is a
         result of the expansion of the Roku Channel. Similarly, address
whether your
         arrangements with advertisers for the Roku Channel significantly
differ from your
         advertising arrangements for the rest of your platform segment, and
how that could impact
         your results of operations and financial condition.
        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 Lisa Etheredge, Staff Accountant, at (202) 551-3424 or
Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Joshua
Shainess,
Attorney-Adviser, at (202) 551-7951 or Larry Spirgel, Assistant Director, at
(202) 551-3810 with
any other questions.



FirstName LastNameAnthony Wood                               Sincerely,
Comapany NameRoku, Inc.
                                                             Division of
Corporation Finance
December 26, 2018 Page 2                                     Office of
Telecommunications
FirstName LastName