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April 16, 2024
Sonalee Parekh
Chief Financial Officer
RingCentral, Inc.
20 Davis Drive
Belmont, CA 94002
Re:RingCentral, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-36089
Dear Sonalee Parekh :
            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 Fiscal Year Ended December 31, 2023
Non-GAAP Adjusted, Unlevered Free Cash Flow, page 71
1.You disclose non-GAAP adjusted, unlevered free cash flow that adds back net cash paid
for interest and restructuring and other payments. You also state that this measure is useful
information to management and investors in understanding the strength of liquidity and
available cash. Tell us how you considered the guidance in Item 10(e)(1)(ii)(A) of
Regulation S-K which prohibits excluding charges that will require cash settlement from a
non-GAAP liquidity measure.
Notes to Consolidated Financial Statements
Note 1. Description of Business and Summary of Significant Accounting Policies
Asset Write-down Charges, page 89
2.We note your disclosure indicating that asset write-down charges consist of write-offs
whenever events or changes in circumstances have occurred that could indicate the
carrying amount of such assets may not be recoverable. In future filings, please clarify
your disclosure here and on page 63 to explain how you determine the amount of any

 FirstName LastNameSonalee  Parekh
 Comapany NameRingCentral, Inc.
 April 16, 2024 Page 2
 FirstName LastName
Sonalee  Parekh
RingCentral, Inc.
April 16, 2024
Page 2
impairment loss whenever these events or change in circumstances occur. Refer to ASC
340-40-35-3.
Controls and Procedures
Management's Annual Report on Internal Controls Over Financial Reporting, page 113
3.Please revise to disclose management's conclusion on the effectiveness of your internal
controls over financial reporting. Refer to Item 308(a)(3) of Regulation S-K.
            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 Melissa Walsh at 202-551-3224 or Stephen Krikorian at 202-551-3488
with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology