SecProbe.io

Mail Stop 3030
June 2 , 2016

Via E -mail
Brian McGee
Chief Financial  Officer
GoPro, Inc.
3000 Clearview Way
San Mateo, CA  94402

Re: GoPro, Inc.
  Form 10 -K for the Fiscal Year Ended December 31 , 2015
Filed February 2 9, 2016
File No. 001 -36514

Dear Mr. McGee :

We have reviewed  your May 25, 2016 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 busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and cir cumstances, 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 May 12,
2016 letter .

Form  10-K for the Fiscal Year Ended December 31, 2015

Item 8.  Financial Statements

Note 2.  Summary of Significant Accounting Policies

Point of purchase (POP) displays, page 58

1. We note from your response to comment 3 that you classify the cash outflows of  POP
displays as operating activities and not investing activities.  Please explain to us how you
considered ASC 230 -10-45-13(c).

Brian McGee
GoPro, Inc.
June 2 , 2016
Page 2

 Note 8. Income Taxes

Uncertain income tax positions, page 73

2. The revised disclosure included in your response to comment 4 addresses the nature of
the events that could occur in the next 12 months, but it does not appear to address the
requirement of ASC 740 -10-50-15(d)(1) for disclosure of the nature of the uncerta in tax
position.  Please revise your disclosure in future filings.  Also r efer to ASC 740 -10-55-
217.

Product warranty, page 75

3. In your response to comment 6 you told us  that warranty costs increased in 2015 due, in
part, to significant revenue grow th in the fourth quarter of 2014.  Please explain to us
why the warranty costs attributable to 2014 revenue increased warranty expenses in 2015.
In addition, please clarify for us why warranty costs as a percentage of revenue increased
in the first quarte r of 2015 when compared to the preceding quarter.

Acknowledgements

4. As previously requested, 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 Michael Fay at 202 -551-3812 , or Kate  Tillan, Assistant Chief
Accountant,  at 202 -551-3604  with any questions .  You may also reach me at 202-551-3671.

Sincerely,

 /s/ Kate Tillan for

 Martin James
Senior Assistant Chief Accountant
Office of Electronics and Machinery