CORRESP

December 9, 2019

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549


Re:	Bill.com Holdings, Inc.
	Registration Statement on Form S-1
	File No. 333-234730

	Acceleration Request
	Requested Date:	December 11, 2019
	Requested Time:	4:00 p.m., Eastern Standard Time

Ladies and Gentlemen:

Pursuant to Rule 460 under the Securities Act of 1933, as amended (the “Securities Act”), we, the representatives of the underwriters (the “Representatives”), wish to advise you that between December 2, 2019 and the date hereof, we have distributed approximately 3,601 copies of the Preliminary Prospectus of Bill.com Holdings, Inc., a Delaware corporation (the “Registrant”), dated December 2, 2019, to underwriters, dealers, institutional investors and others.

We, the undersigned Representatives, have and will, and have been informed by the participating underwriters that they have and will, comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the proposed offering.

In accordance with Rule 461 of the Securities Act, we hereby join in the request of the Registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m. Eastern Standard Time on December 11, 2019, or as soon thereafter as practicable. We, the undersigned Representatives, confirm that the underwriters are aware of their obligations under the Securities Act.

[Signature Page Follows]


Very truly yours,

Goldman Sachs & Co. LLC BofA Securities, Inc. Jefferies LLC

As representatives of the several underwriters listed in Schedule I to the Underwriting Agreement

Goldman Sachs & Co. LLC

By:		/s/ Jeffrey M. Gido
		Name: Jeffrey M. Gido
		Title: Managing Director

BofA Securities, Inc.

By:		/s/ Magdalena Heinrich
		Name: Magdalena Heinrich
		Title: Managing Director

Jefferies LLC

By:		/s/ C. Cullom Davis
		Name: C. Cullom Davis
		Title: Vice Chairman