August 13, 2019

Ray Winborne
Chief Financial Officer
GoDaddy Inc.
14455 N. Hayden Road
Scottsdale, Arizona 85260

       Re: GoDaddy Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 22, 2019
           Form 10-Q for the Quarterly Period Ended June 30, 2019
           Filed August 2, 2019
           File No. 001-36904

Dear Mr. Winborne:

       We have reviewed your filing 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 the comment we may have additional
comments.

Form 10-Q for the Quarterly Period Ended June 30, 2019

Note 11. Commitments and Contingencies
Litigation, page 19

1.    We note your disclosures regarding the agreement in principle to settle
the class action
      complaint. Please describe for us the terms, obligations and rights
associated with the
      proposed settlement and describe your proposed accounting for each of the
elements of
      the settlement. As part of your response, explain your basis for only
accruing $18 million
      of the $35 million settlement. Also, explain why the amounts related to
class members
      who elect to receive credits for future purchases will be classified as
an offset to revenue
      and why these amounts will be recorded in the future as purchases are
made. We refer
      you to ASC 450-20-25-2.
 Ray Winborne
GoDaddy Inc.
August 13, 2019
Page 2

        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 Eiko Yaoita Pyles, Staff Accountant at 202-551-3587 or
Christine
Dietz, Assistant Chief Accountant, at 202-551-3408 if you have any questions.



                                                          Sincerely,
FirstName LastNameRay Winborne
                                                          Division of
Corporation Finance
Comapany NameGoDaddy Inc.
                                                          Office of Information
Technologies
August 13, 2019 Page 2                                    and Services
FirstName LastName