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 Document Rapid7 120 Causeway Street Suite 400 Boston, MA 02114-1313 rapid7.com VIA EDGAR SUBMISSION August 5, 2025 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, N.E. Washington, D.C. 20549 Attention: Lisa Etheredge and Robert Littlepage Re: Rapid7, Inc. Form 10-K for the Year Ended December 31, 2024 File No. 001-37496 Dear Ms. Etheredge and Mr. Littlepage: Rapid7, Inc. (the “Company”) respectfully submits this letter in response to the comment letter dated July 31, 2025, from the staff of the U.S. Securities and Exchange Commission (the “Staff”) with respect to the Company’s Form 10-K for the year ended December 31, 2024 (the “Form 10-K”). The Company has carefully reviewed the Staff’s comments and provides the responses below. The Company will revise its disclosures in future filings, beginning with the Form 10-Q for the quarter ended June 30, 2025 (“Q2 2025 Form 10-Q”), in response to the Staff’s comments. Form 10-K for the Year Ended December 31, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Results, page 43 1. To avoid giving undue prominence to non-GAAP measures, please revise to move your discussion of non-GAAP information so that it follows the discussion of GAAP results of operations. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and the guidance in Non-GAAP Compliance and Disclosure Interpretation Question 102.10(a). Company Response: The Company acknowledges the Staff’s comment and will revise the Management’s Discussion and Analysis of Financial Condition and Results of Operations section in future filings to ensure that discussion of non-GAAP financial information follows the discussion of the Company’s GAAP Results of Operations. This change will be reflected beginning with the Q2 2025 Form 10-Q. 1 Consolidated Financial Statements (18) Segment Information and Information about Geographic Areas, page 91 2. Please revise to disclose revenues from external customers and property and equipment attributed to the United States. Refer to ASC 280-10-50-41. Company Response: The Company acknowledges the Staff’s comment and will revise the disclosures in the notes to the consolidated financial statements to include revenue from external customers and property and equipment attributed to the United States, in accordance with ASC 280-10-50-41. These disclosures will be included beginning with the Q2 2025 Form 10-Q, as proposed below. For fiscal years 2024, 2023, and 2022, the United States was the only country where external customer revenue exceeded 10% of the Company’s total revenue. Net revenues by geographic area presented based upon the location of the customer are as follows: Three Months Ended, June 30, Six Months Ended, June 30, 2025 2024 2025 2024 (in thousands) United States $ XXX,XXX $ 152,204  $ XXX,XXX $ 302,449  Rest of World $ XXX,XXX 55,787  $ XXX,XXX $ 110,643  Total $ XXX,XXX $ 207,991   $ XXX,XXX $ 413,092   Property and equipment, net by geographic area was as follows: As of June 30, 2025 As of December 31, 2024 (in thousands) United States $ XXX,XXX $ 22,613  Rest of World $ XXX,XXX $ 9,632  Total $ XXX,XXX $ 32,245   The Company appreciates the Staff’s review of the Form 10-K and the opportunity to enhance its disclosures. Please contact the undersigned at Tim_Adams@Rapid7.com, or Peter Kaes at Peter_Kaes@Rapid7.com, if you have any further questions or require additional information. Sincerely, /s/Tim Adams Chief Financial Officer Rapid7, Inc. 2