Michael A. Brown March 30, 2021 Email mbrown@fenwick.com
Direct Dial +1 (415) 875-2432

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:	Melissa Rocha
	Dietrich King
	J. Nolan McWilliams
	Sonia Bednarowski
	John Spitz
	Michael Volley
Re:	Coinbase Global, Inc. Registration Statement on Form S-1 File No. 333-253482

Ladies and Gentlemen:

On behalf of Coinbase Global, Inc. (the “Company”), we are submitting this letter to confirm to the staff of the U.S. Securities and Exchange Commission that the Company will endeavor, and it is our understanding that the financial advisors and any affiliated persons each will endeavor, to conduct its and their activities in connection with the public offering being conducted pursuant to the above-captioned Registration Statement on Form S-1 in compliance with Regulation M (to the extent that Regulation M applies to such activities).

Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at (310) 434-5401, or, in his absence, Ran Ben-Tzur at (310) 434-5403.

* * *

Sincerely,
By:	/s/ Michael A. Brown
	Michael A. Brown
	Partner
	FENWICK & WEST LLP

cc:	Brian Armstrong, Chief Executive Officer
	Alesia J. Haas, Chief Financial Officer
	Paul Grewal, Esq.
	Juan Suarez, Esq.
	Doug Sharp, Esq.
	Coinbase Global, Inc.

Mark Stevens, Esq.

Ran Ben-Tzur, Esq.

Faisal Rashid, Esq.

Jennifer Hitchcock, Esq.

Fenwick & West LLP