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May 24, 2024
Kate Bueker
Chief Financial Officer
HubSpot, Inc.
Two Canal Park
Cambridge, MA 02141
Re:HubSpot, Inc.
10-K filed February 14, 2024
File No. 001-36680
Dear Kate Bueker :
            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
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Investments, page 75
1.Please tell us and revise future filings to clarify how your impairment policy for debt
investments classified as available-for-sale securities complies with the guidance in ASC
326-30-35. In this regard, we note your policy involves making a determination as to
whether the unrealized loss is other-than-temporary. Provide us with your analysis of the
materiality of the impact from any correction of your policy.
Leases, page 77
2.You indicate that operating lease liabilities and related expenses are recorded as incurred
for short-term leases. Please tell us and revise future filings to clarify how your policy
complies with the guidance in ASC 842-20-25-2 that, although variable lease payments
should be recognized as incurred, lease payments should be recognized on a straight-line
basis over the lease term.

 FirstName LastNameKate Bueker
 Comapany NameHubSpot, Inc.
 May 24, 2024 Page 2
 FirstName LastName
Kate Bueker
HubSpot, Inc.
May 24, 2024
Page 2
3.We note your disclosure that the net present value of future lease payments is determined
using the Company’s incremental borrowing rate because your operating leases do not
provide an implicit rate. Tell us how your determination of the discount rate for the lease
complies with the guidance in ASC 842-20-30-3. That is, even though your operating
leases do not provide an implicit rate, explain whether the rates implicit in any of your
leases are readily determinable from information provided in the lease.
Stock-Based Compensation, page 80
4.We note your disclosure that stock-based compensation costs for awards with
performance conditions is recognized on the graded vesting attribution method over the
requisite service period. Please tell us and disclose in future filings what consideration
was given to the guidance in ASC 718-10-30-28 that compensation costs for awards with
performance conditions should be recognized if and when it is probable that the
performance target will be achieved.
            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
cc:       Alyssa Harvey Dawson