SecProbe.io

September 27, 2013

Via E -Mail
Peter Gassner
President, Chief Executive Officer and Director
Veeva Systems , Inc.
4637 Chabot Drive, Suite 210
Pleasanton, California 94588

Re: Veeva  Systems, Inc.
Amendment No. 2 to Registration Statement on Form S -1
Filed  September 23 , 2013
File No. 333-191085

Dear Mr. Gassner:

We have rev iewed your letter dated September 23, 2013  and the above -referenced
registration statement  and have the following comments.  Where we reference prior comments,
we are referring to our letter dated September 10, 2013.

Results of Operations

Six Months Ended July 31, 2012 and 2013

Revenues, page 52

1. We note that within your common stock valuations, particularly your May 2013 and July
2013 valuations discussed on page 71, you identify the introduction of your Veeva CRM
Approved Email solution as one of the factors that caused the valuation of your common
stock to increase .  In light of this solution impacting your common stock valuation, please
explain why revenue recognized from this solution is not similarly identified and
quantified as impacting revenues for the six months ended July 31, 2013.

Critical Accounting Poli cies and Estimates

Stock -Based Compensation

Common Stock Valuations, page 64

2. We note your response to prior comment 3.   Please explain to us and revise your
disclosure to indicate why you believe the February 14, 2013 announcement of Veeva
CRM Approved Email was not significant for the valuation of the March 2013 issuances

Peter Gassner
Veeva Systems, Inc.
September 27, 2013
Page 2

 while it was for the April 30, 2013 valuation considering that no orders had generated
revenues as of either the March 2013 issuances or the April 30, 2013 valuation.  In other
words, what led to greater significance of the announcement for the April 30, 2013
valuation absent any revenues to date?

3. Revise your disclosure related to the valuation of the March 2013 issuance to explain
more fully your reliance on the relevance of the Janua ry 31, 2013 valuation in view of the
fact you were nearly half way into a quarter that saw a 7.5% quarterly increase in
revenues.   Consider addressing in revised disclosure whether the increase in revenues in
the quarter were preceded by orders and interes t known as of the March issuances.   Given
the importance of the impact of the Veeva CRM Approved Email solution in your April
30, 2013 and June 30, 2013 valuations tell us and disclose what interest or actual orders
related to the Veeva CRM Approved Email were known or knowable at the March 2013
issuances and informed forecasted or actual revenue that impacted revised financial
forecasts used for the April 30, 2013 and June 30, 2013 valuations.

4. Explain why you believe the additional IPO steps taken since  the March 2013
issuance   that only led to a decrease in the non -marketability discount of 2.5%
contributed significantly to the 45 % increased stock valuation over the quarter.

 You may contact Ryan Rohn, Staff Accountant, at (202) 551 -3739, or Craig Wilson, Senior
Assistant Chief Accountant at (202) 551 -3226, if you have questions regarding comments on the
financial statements and related matters.  Please contact Ivan Griswold, Staff Attorney , at (202) 551 -
3853 or, in his absence, me at (202) 551 -3488 with any other questions.

Sincerely,

 /s/ Matthew Crispino

Matthew Crispino
        Staff Attorney

cc: Via E -Mail
 Brian C. Patterson, Esq.
 Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP