February 11, 2020

Craig Courtemanche
President and Chief Executive Officer
Procore Technologies, Inc.
6309 Carpinteria Avenue
Carpinteria, California 93013

       Re: Procore Technologies, Inc.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted February 4, 2020
           CIK No. 0001611052

Dear Mr. Courtemanche:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
January 22, 2020 letter.

Amendment No. 2 to Draft Registration Statement on Form S-1

Prospectus Summary, page 1

1.     You state in your response to prior comment 1 that your reference to the
"number of users
       brought onto our platform" is referring to the number of users invited
to the platform
       during the period. Please clarify whether each invited user actually
logged on and used
       your platform during the period. If not, explain the relevance to your
operations of
       disclosing 170 users on average per customer. With regard to the 1.3
million users, please
       tell us whether a user can be counted more than once. In this regard, in
your January 13,
       2020 response to comment 7, you indicated that collaborators can use a
variety of
       different log-in credentials and devices to access your platform. To the
extent that a
 Craig Courtemanche
Procore Technologies, Inc.
February 11, 2020
Page 2
      collaborator can be counted more than once during the period, tell us how
this factored
      into your calculations of total users, and revise your disclosures to
clarify the limitations
      of this measure, as applicable.
General

2.    We note the artwork on the inside front cover page of the prospectus
includes a
      presentation of revenue without an equally prominent presentation of net
loss. Please
      revise. Refer to Question 101.02 of our Securities Act Forms Compliance
and Disclosure
      Interpretations.
        You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or
Kathleen Collins,
Accounting Branch Chief, at (202) 551-3499 if you have questions regarding
comments on the
financial statements and related matters. Please contact Bernard Nolan,
Attorney-Adviser, at
(202) 551-6515 or, in his absence, Larry Spirgel, Office Chief, at (202)
551-3815 with any other
questions.



                                                              Sincerely,
FirstName LastNameCraig Courtemanche
                                                              Division of
Corporation Finance
Comapany NameProcore Technologies, Inc.
                                                              Office of
Technology
February 11, 2020 Page 2
cc:       Peter N. Mandel
FirstName LastName