November 1, 2018

Jack Dorsey
Chief Executive Officer
Square, Inc.
1455 Market Street, Suite 600
San Francisco, CA 94103

       Re: Square, Inc.
           Form 10-Q for the Quarter Ended March 31, 2018
           Filed May 2, 2018
           Form 10-Q for the Quarter Ended June 30, 2018
           Filed August 1, 2018
           File No. 001-37622

Dear Mr. Dorsey:

        We have reviewed your August 28, 2018 response to our comment letter
and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our August 16, 2018 letter.

Form 10-Q for the Quarter Ended June 30, 2018

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Key Operating Metrics and Non-G AAP Financial Measures
Adjusted Revenue, page 39

1.    Your adjusted revenue measure includes adjustments for transaction-based
costs and
      bitcoin costs. Explain to us why you believe this measure does not
substitute individually
      tailored recognition and measurement methods for those of GAAP. Refer to
Question
      100.04 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
 Jack Dorsey
Square, Inc.
November 1, 2018
Page 2


      You may contact Laura Veator, Staff Accountant, at 202-551-3716 or
Stephen Krikorian,
Accounting Branch Chief, at 202-551-3488 with any questions.



                                                        Sincerely,
FirstName LastNameJack Dorsey
                                                        Division of Corporation
Finance
Comapany NameSquare, Inc.
                                                        Office of Information
Technologies
November 1, 2018 Page 2                                 and Services
FirstName LastName