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                             June 24, 2020

       Brian Roberts
       Chief Financial Officer
       Lyft, Inc.
       185 Berry Street
       Suite 5000
       San Francisco, CA 94107

                                                        Re: Lyft, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2019
                                                            Filed February 28,
2020
                                                            File No. 001-38846

       Dear Mr. Roberts:

              We have reviewed your filing 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 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-K for the Year Ended December 31, 2019

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       Operations and Support, page 66

   1.                                                   Please tell us your
consideration of the acquisition and ongoing maintenance of your
                                                        network of shared bikes
and scooters as you only include 'direct costs' in your cost of
                                                        revenues. Certain costs
of ongoing maintenance and support of this network appear
                                                        integral to the
generation of this revenue source and should be included in cost of
                                                        revenues. In this
regard, we note 'Operations and support costs' increased almost $300
                                                        million in 2019 in
conjunction with the expansion of your network of shared bikes and
                                                        scooters. Refer to Rule
5-03(b)(2) of Regulation S-X.
 Brian Roberts
FirstName LastNameBrian Roberts
Lyft, Inc.
Comapany NameLyft, Inc.
June 24, 2020
Page 2
June 24, 2020 Page 2
FirstName LastName
Non-GAAP Financial Measures
Contribution and Contribution Margin
Reconciliation of Non-GAAP Financial Measures, page 70

2.       Referencing the adjustment 'Changes to the liabilities for insurance
required by
         regulatory agencies attributable to prior periods' used to calculate
the Non-GAAP
         financial measures contribution and contribution margins, please
explain to us why
         increases in insurance reserves is not considered part of the
recurring operating
         expenditures of your business. Refer to Questions 100.01 and 100.04 of
the Compliance
         and Disclosure Interpretations on Non-GAAP Financial Measures, updated
April 4, 2018.
Notes to Consolidated Financial Statements
Note 4. Goodwill and Intangible Assets, Net, page 96

3.       Please explain to us how you determined the future amortization of
intangible assets,
         specifically for contractual relationships, that will be recorded in
cost of revenue and
         operating expenses for the next five years and thereafter. In your
response, please address
         how you assigned useful lives of 3-12 years to 'Contractual
relationships - cities' for those
         intangible assets acquired from Motivate in 2018 disclosed on page 95.
It appears your
         overall amortization of intangibles will decline from $35 million in
2019 to approximately
         $25 million and $13 million in 2020 and 2021, respectively.
Note 7. Leases
Flexdrive Program, page 101

4.       We note you disclose the right-of-use (ROU) assets and liabilities for
vehicles leased as
         part of your Flexdrive Program, but do not disclose vehicles leased as
part of your Lyft
         Rentals programs which was tested in two major metropolitan areas in
2019 as a flexible
         car rental program. Please tell us and disclose in this note vehicles
leased as part of Lyft
         Rentals, if material, that are included on your balance sheet at
December 31, 2019. Refer
         to ASC 842-30-50.
 Brian Roberts
FirstName LastNameBrian Roberts
Lyft, Inc.
Comapany NameLyft, Inc.
June 24, 2020
June 24, 2020 Page 3
Page 3
FirstName LastName
        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 Robert Shapiro, Senior Staff Accountant, at (202)
551-3273 or Amy
Geddes, Senior Staff Accountant, at (202) 551-3304 if you have questions
regarding comments
on the financial statements and related matters. Please contact Jacqueline
Kaufman, Staff
Attorney, at (202) 551-3797 or Mara Ransom, Office Chief, at (202) 551-3264
with any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:      Lisa Stimmell