SecProbe.io

May 9, 2013

Via E -mail
Michael P. Scarpelli
Chief Financial Officer
ServiceNow, Inc.
4810 Eastgate Mall
San Diego, CA 92121

Re: ServiceNow, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2012
Filed March 8, 2013
File No. 001 -35580

Dear Mr. Scarpelli :

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 circumstances 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.

Notes to Consolidated Financial Statements

Note (2) Summary of Significant Accounting Policies

Revenue Recognition, page 63

1. We note that you sell services through your direct sales force as well as indirect channels
which include resellers and system integrators.  Please explain any differences in sales ,
credit and collection terms, as well as any differences in how each of the basic revenue
recogni tion criteria is met, for sales through indirect channels compared to direct sales.

2. With regard to evidence of an arrangement , we note that historically when you did not
have a signed contract a purchase order or a signed order form  was considered to

Michael P. Scarpelli
ServiceNow, Inc.
May 9, 2013
Page 2

 represent evidence of an arrangement .  We further note that in situations where you have
both a signed contract and either a purchase order or signed order form, you consider the
signed contract to represent  the final persuasive evidence of an arrangement.   Please
explain in further detail, your current and historical customary practices for obtaining
evidence of an arrangement and tell us whether there are differences based on type of
customer or sales channel.  Also, please clarify the implications, if any , of using a signed
contract rather than a purchase order or signed order form as evidence of an arrangement.

3. Where you rely upon a purchase order as evidence of an arrangement , please tell us how
you determine that the terms of the purchase order comply  with your required terms of
sale.  In this regard, your use of written purchase orders issued by the customer as
evidence of an arrangement should be c larified.  Please tell us if the purchase order terms
in all cases reflect your normal sales agreement c onditions .

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 they 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 securities laws of the United States.

You may contact David Edgar, Staff Accountant , at (202) 551 -3459  if you have questions
regarding comments on the financial statements and re lated matters.  Please contact me at (202)
551-3226  with any other questions.

Sincerely,

 /s/ Craig D. Wilson

Craig D. Wilson
Sr. Asst. Chief Accountant