SecProbe.io

February 17, 2015

Via E -mail
Brian Carolan
Vice President and Chief Financial Officer
CommVault Systems, Inc.
1 CommVault Way
Tinton Falls, NJ 07724

Re: CommVault Systems, Inc.
 Form 10-K for the Fiscal Year Ended March 31, 2014
Filed May 2, 2014
File No. 001 -33026

Dear Mr. Carolan :

We have reviewed your filing an d have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstance s or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment s, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended March 31, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations,
page 33

General

1. We note that you generate a significant amount of revenue outside of the United States;
however, you do not disc uss or quantify the results of your international operations by
country or region.  In your earnings call for the year ended March 31, 2014 , as well as
subsequent earnings calls , you frequently refer to activities by geographic region,
specifically  EMEA, A mercias and APAC.  These references by region include:
describing performance; quantifying customer base; noting organization of sales force;

Brian Carolan
CommVault Systems, Inc.
February 17, 2015
Page 2

 and discussing investments, restructuring and “turnaround” activity.  Therefore it appears
that you  consider geographic information  relevant to your business and operat ing results.
Please tell us your consideration of incorporating a discussion here in future filings
regarding your geographic regions to inclu de: identifying these regions and the countries
of which they consist, quantifying revenue and gross margin by region for each period
presented, discussing material changes in results, significant or unusual events, as well as
known trends and uncertaintie s.  Please provide any proposed disclosures in your
response. We refer you to  Refer to Item 303(a) of Regulation S -K and Section III.B of
SEC Release No. 33 -8350.

Notes to Consolidated Financial Statements

Note 10 Segment Information, page 71
2. You disclo se that you operate in one reportable segment, storage software solutions.  You
further state that your chief operating decision maker (“CODM”) evaluates the
performance of the company presented on a consolidated basis, accompanied by
information about rev enue by geographic region for purposes of tracking distribution of
resources and analyzing overall return on investment for both domestic and international
operations.  However, based on the presentation of information, discussion, and analysis
noted in th e earnings calls, as described in the comment above, it appears the CODM
does make decisions about resources and assesses performance based on geographic
region.  Please tell us how the company has determined it operates in one reportable
segment and why t hese geographic regions are not considered separate reportable
segments under ASC 280 -10-50.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the  Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures t hey have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in  response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securit ies laws of the United States.

Brian Carolan
CommVault Systems, Inc.
February 17, 2015
Page 3

 You may contact David Edgar, Staff Accountant , at (202) 551 -3459  or Melissa Kindelan,
Staff Accountant , at (202) 551 -3564 if you have questions regarding comments on the financial
statements and re lated matters.  Please contact me at (202) 551 -3406  with any other questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief