SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 17, 2025

Jennifer DiRico
Chief Financial Officer
Commvault Systems, Inc.
1 Commvault Way
Tinton Falls, New Jersey 07724

 Re: Commvault Systems, Inc.
 Form 10-K for the Fiscal Year Ended March 31, 2025
 File No. 001-33026
Dear Jennifer DiRico:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Year Ended March 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 30

1. We note your present annual recurring revenue (ARR) and subscription ARR
in your
 Item 2.02 Form 8-K earnings releases and you refer to such measures as
"KPIs" in
 your investor presentation. We also note you present other measures such
as SaaS net
 dollar retention rate and subscription customer growth in your investor
presentations.
 Please tell us your consideration to include these measures in your Form
10-Q and 10-
 K filings. In addition, tell us whether management uses any other key
performance
 measures in evaluating your business and if so, revise to include a
qualitative and
 quantitative discussion of such metrics. Refer to SEC Release No.
33-10751.
Results of Operations, page 35

2. We note you refer to several factors impacting the period-over-period
change in
 operating expenses, however, you only quantify the impact of stock-based
 compensation. Where a material change is attributed to two or more
factors, including
 June 17, 2025
Page 2

 any offsetting factors, revise to describe the contribution of each
factor in quantified
 terms. Refer to Item 303(b) of Regulation S-K.
Consolidated Statements of Operations, page 47

3. We note subscriptions includes revenues from both products (i.e., the
software portion
 of term-based licenses) and services (SaaS offerings). Please tell us
the amount of
 term-based license software revenue included in this line item for each
period
 presented. Also, tell us your consideration to separately present
revenue from these
 products and services pursuant to Rule 5-03(b) of Regulation S-X.
Notes to Consolidated Financial Statements
Note 3. Revenue
Disaggregation of Revenues, page 59

4. Please tell us what consideration was given to disaggregating revenue
between point-
 in-time and over-time recognition. In this regard, we note your
subscription revenues
 include both term-based software license revenues that are recognized
up-front and
 SaaS revenues, which are recognized over-time. Refer to ASC 606-10-50-5
and 55-89
 through 91.
Note 14. Segment Information, page 72

5. We note the CODM uses consolidated net income (loss) to measure segment
profit or
 loss, allocate resources and assess performance. Please revise to
discuss how the
 CODM uses this measure in assessing segment performance and deciding how
to
 allocate resources. Refer to 280-10-50-29(f) and the example at
280-10-55-54(c).
 In closing, 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.

 Please contact Chen Chen at 202-551-7351 or Kathleen Collins at
202-551-3499 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Danielle Sheer
</TEXT>
</DOCUMENT>