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April 5, 2023
Aidan Viggiano
Chief Financial Officer
Twilio Inc.
101 Spear Street, Fifth Floor
San Francisco, California 94105
Re:Twilio Inc.
Form 8-K Filed February 13, 2023
Response dated March 8, 2023
File No. 001-37806
Dear Aidan Viggiano:
            We have reviewed your March 8, 2023 response to our comment letter and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
February 2, 2023 letter.
Form 8-K Filed February 13, 2023
General
1.In light of the organizational changes described in your Form 8-K filed February 13, 2023
that were effective during the three months ended March 31, 2023, provide us with your
updated ASC 280 segment identification analysis.  In your analysis, please tell us if there
have been any changes in your identified operating and reportable segments, and
specifically address how you considered the following in determining your identified
operating and reportable segments:
•the changes in your management structure, including the identity and role of each of
your segment managers, how your company is organized, and when such changes
were effective;
•what the key operating decisions are, who makes them, and how resources are

 FirstName LastNameAidan Viggiano
 Comapany NameTwilio Inc.
 April 5, 2023 Page 2
 FirstName LastName
Aidan Viggiano
Twilio Inc.
April 5, 2023
Page 2
allocated and performance is assessed within your business;
•how the CODM and direct reports are compensated; and
•how often the CODM meets with his direct reports, the financial information he
reviews in conjunction with those meetings, the financial information discussed, and
who else attends such meetings.

2.As part of your updated segment identification analysis, describe the financial information
reviewed by the CODM for the purpose of allocating resources and assessing
performance, and provide us with a sample of the internal financial reporting package that
the CODM receives and/or discusses with his direct reports. In this regard, we note from
your prior response that your CODM previously received the monthly Executive Team
Report, which included product-level margin percentage information and commentary
explaining variances against the company’s forecast and prior periods.  Your response to
prior comment 1 from our letter dated February 2, 2023 also stated that product-level
gross margin information was used by the CODM to understand and explain trends and
variances in the consolidated gross margins. If your CODM continues to receive lower
level financial information following the reorganization, such as at the product level,
describe this information in detail, how it is used, and tell us why operating segments were
not identified at that level. Finally, describe the financial information reviewed by your
Board of Directors and how frequently that information is reviewed.
3.Explain to us how your 2023 budget was prepared, who approved the budget at each step
of the process, the level of detail discussed at each step, the level of detail received by the
CODM, and the level at which the CODM makes changes to the budget. Additionally, tell
us if your 2023 budget information is prepared in the same or a different format as your
current internal reporting package, and if it includes product margin or other lower level
information.
4.In light of your organizational changes, tell us if you have re-considered your prior
goodwill reporting unit determination.  If so, please provide us with your analysis. Refer
to ASC 350-20.
            You may contact Inessa Kessman, Senior Staff Accountant, at (202) 551-3371 or Lisa
Etheredge, Senior Staff Accountant, at (202) 551-3424 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Rezwan Pavri