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    VIA EDGAR

    December 6, 2023

    Office of Finance

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

Washington, D.C. 20549-3628

Attn:

    William Schroeder

    Michael Volley

    Re:
    Goosehead Insurance, Inc.

    Form 10-K for Fiscal Year Ended December 31, 2022

    File No. 001-38466

Dear Mr. Schroeder and Mr. Volley:

On behalf of Goosehead Insurance, Inc.,
a Delaware corporation (the “Company”), this letter sets forth the Company’s responses to the comment letter
of the Staff of the Securities and Exchange Commission (the “Staff” of the “Commission”) dated
October 25, 2023, issued in response to the Company’s letter dated October 13, 2023 in response to the Staff’s initial comment
letter dated September 18, 2023, all relating to the Company’s Form 10-K for the fiscal year ended December 31, 2022.

For your convenience, we have reproduced
the Staff’s comments preceding the Company’s responses below. Please let us know if you have any questions or if we can provide
additional information or otherwise be of assistance in expediting the review process.

Form 10-K filed February 27, 2023

Company Overview, page 5

 1. Please refer to prior comment
                                            1. We note you state in your response that it is difficult to determine exact profitability
                                            of each agent network (i.e., corporate vs. franchise). We also note in your June 30, 2023
                                            earnings conference call you state that, “As we continue to launch more corporate agents
                                            into franchises, this creates a near-term trade-off on revenue growth because of the differences
                                            in revenue recognition but significantly benefits longer-term revenue and profitability as
                                            the productive life of the agent increases and they duplicate themselves through producer
                                            hiring.” Please clarify the meaning of this statement for us specific to the reference
                                            to the longer-term profitability of an agent. Also, to the extent that there are material
                                            differences

in the longer-term profitability
or margin in an agent network (i.e., corporate vs. franchise), please revise your business section in future filings to discuss this.

Response

The Company respectfully
acknowledges the Staff’s comment and further clarifies the referenced statements as follows. The Company is organized such that
it operates and supports both corporate sales and franchise sales distribution networks within the same organizational structure. As
such, Company resources are shared to support both networks, including, for example, service agents, training/licensing operations, and
support functions. Management reviews financial results on a consolidated basis, as the Company does not allocate costs between the networks.

The Company notes that the
comment from the June 30, 2023 earnings conference call referenced by the Staff is in reference to the profitability of the franchise
started by a corporate agent as compared to an individual corporate agent and relates to two drivers of long-term revenue and profitability
that differ between the two. First, the Company tracks the average tenure of corporate agents and franchise agents and notes that the
average tenure is longer for franchise agents, which results in incremental policies placed over the longer tenure. Second, and more
importantly, as a successful corporate agent launches a franchise and then begins to hire, train, and support (at their expense) additional
producers for their franchise, the volume of policies placed, and thus revenue and profit generated, by that franchise increases in comparison
to the revenue and profit generated if that corporate agent remained an individual producer.

Prior to 2022, only six corporate
agents had converted to franchise owners. Since 2022, the Company has begun to focus on conversion as a mutually-beneficial career path
opportunity for corporate agents. Since 2022 through June 30, 2023, 25 corporate agents have become franchise owners, 14 having converted
in 2023. These franchises had a combined 11 additional producers working for their agencies as of June 30, 2023. Furthermore, as of June
30, 2023, the Company had 1,344 operating franchises with a total of 2,069 producers; as such, the overall impact of these conversions
has not had a significant impact on the Company’s revenues or profitability to date.

3. Revenues - Commissions
and agency fees, page 79

 2. Please refer to prior comment
                                            2. We note your disclosure on page 79 that you earn new and renewal commissions paid by insurance
                                            carriers for the binding of insurance coverage and that these commissions are earned at a
                                            point in time upon

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the effective date of
bound insurance coverage, as no performance obligation exists after coverage is bound. We also note disclosure in the critical audit
matter on page 69 related to management’s estimates to constrain renewal commissions. Please clarify for us if renewal commissions
represent variable consideration, are included in the transaction price and are fully constrained and revise your accounting policy disclosure
in future filings to more clearly state this, if true. If not true, please more clearly tell us how you determined that renewal commissions
are a separate performance obligation, why you disclose that no performance obligations exist after coverage is bound, why renewal commissions
are not variable consideration, and why they should not be included in the transaction price based on the guidance in ASC 606-10-05-4
and ASC 606-10-32-5. Please include the guidance you considered and the relevant terms of the contract(s) with insurance carriers in
making your accounting determinations.

Response

The Company respectfully
acknowledges the Staff’s comment and has included below a discussion of the considerations regarding the accounting treatment of
commissions revenue and its accompanying disclosures. The discussion includes consideration of the following concepts that are fundamental
to determining the accounting policy for the recognition of commissions revenue:

 · The
                                            Company’s customer is the individual consumer seeking insurance coverage (the insured)

 · The
                                            Company is an agent of its customer (the insured) with the performance obligation to arrange
                                            for the provision of the specified service (insurance coverage) by another party (the carrier)
                                            (ASC 606-10-55-38 and 55-317 through 55-319)

 · The
                                            contract with the customer is the Policy Binder (defined below)

 · The
                                            Company maintains contracts with insurance carriers, to facilitate the Company’s ability
                                            to perform its obligations as an agent of the insured (ASC 606-10-55-317 through 55-319)

 · Each
                                            term of a policy is a separate, distinct contract and contains contractual terms unique to
                                            that individual policy term (e.g., premiums, coverage limits, deductibles, and included/excluded
                                            coverages)

 · The
                                            first term of the initial policy for a given insurance product is referred to as a new business
                                            policy and recognized into revenue as a new business commission on the effective date of
                                            the new business policy

 · The
                                            second term of a policy for a given insurance product is referred to as a renewal policy
                                            and recognized into revenue as a renewal commission on the effective date of the renewal
                                            policy for that specific term

 · Each
                                            subsequent policy term for a given insurance product (even if the carrier providing the policy
                                            changes from term to term) is also referred to as a

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renewal policy and recognized
into revenue as renewal commissions on the effective date of that specific term

 · Acceptance
                                            of a renewal policy is subject to the customer’s unilateral right to non-renew, the
                                            customer’s “renewal option” (ASC 606-10-25-4)

 · The
                                            renewal option does not provide the customer with a material right, as the renewal policy
                                            premium (and therefore the associated commission) reflects the standalone selling price of
                                            that policy as the premium is set at the time of each renewal term based on current market
                                            factors (ASC 606-10-5-43)

In consideration of ASC 606-10-05-4
step 1 and ASC 606-10-25-1, and in context of ASC 606-10-15-3, 55-38, 55-317 through 55-319, and paragraph BC186 of ASU 2104-09, the
Company determined that, with regard to new and renewal commissions revenue, the insured is the Company’s customer and each policy
term (typically one year or less) is a separate contract with its customer. Each renewal commission represents a separate policy with
a separate policy term (typically one year or less) and are recognized in revenue on the effective date of each subsequent policy term,
including if a policy is rewritten with a different carrier. As such, renewals represent a separate performance obligation, and therefore
renewal commissions are not included in the transaction price of the initial term of the policy when new business commissions are recognized
and therefore do not represent variable consideration. Additionally, the amount of consideration is fixed per the terms of the insurance
policy. The Company includes an estimate of the consideration that will be foregone as a result of policy cancellations and policy modifications
during that term of the policy within the transaction price. Based on historical experience, these estimates have greater variability
from period to period for renewal policies as compared to new business policies. Therefore, renewal commissions are not constrained as
part of the initial contract; they are constrained in the subsequent contracts to account for the variability in the estimate of foregone
consideration from policy cancellations and modifications.

 I. Identifying the Customer

The Company’s business
is premised on helping consumers identify the best insurance coverage for the best price. In support of that, the Company has created
a unique insurance shopping experience wherein the Company has created a network of over 150 insurance carriers from which it can help
consumers select and place insurance coverage. Given the Company is focused on serving the end consumer by helping them to procure and
make effective a policy that best meets their needs, the Company views the consumer as its customer. The Company considered the following
in making this determination:

 a. Go-to-market strategy: the Company targets
                                            consumers in need of insurance coverage as potential customers, and orients its website and
                                            other marketing

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materials to advertise its
value proposition of having carefully curated a large network of insurance carriers and products, from which the Company will shop on
the consumer’s behalf across that network to identify the best options for the consumer’s needs. As highlighted on the Company’s
website, the Company vets carriers to ensure they meet the needs of their customers. The Company adds new carriers to the network to
expand on a wide range of options to meet consumers’ needs. This vetting process, if successful, results in signing a carrier agreement
that facilitates a more effective shopping experience through inclusion of the carrier in the Company’s proprietary comparison
rater technology (discussed further in section c), and a more efficient binding process for the Company and its customers, as necessary
administrative steps are already established with the relevant carrier.

 b. Carrier agreements:

 o The Company acts as an agent of the consumer
                                            to arrange for the provision of insurance coverage by an insurance carrier. As such, the
                                            insurance carrier fills the role of a supplier to insured.

 o The Company’s carrier agreements
                                            do not require the Company to meet quotas for placing a minimum number of policies, which
                                            is consistent with the Company’s policy to remain agnostic to carriers. Further, the
                                            carrier agreement does not provide the carrier with any enforceable rights and does not place
                                            any substantive performance obligations on the Company until the carrier has bound a policy
                                            and the insured agrees to the terms of the policy in a separate contract. Therefore, the
                                            carrier agreements on their own do not qualify as a stand-alone contract under the revenue
                                            accounting standards.

 o The carrier agreements do not contain
                                            any provisions that prevent or impede the Company’s ability to focus on meeting the
                                            consumer’s needs in selecting a policy by remaining agnostic to which carrier ultimately
                                            offers the policy to the consumer. Further, the Company has created a network of over 150
                                            carriers that allows its agents to curate an insurance solution that best meets the consumer’s
                                            individual needs.

 o The carrier agreements specify that the
                                            carrier does not have the right to solicit the consumer except in relation to potential renewals
                                            of existing policies. In those policy renewals, the carrier does not possess the right legally
                                            or based on customary business practice to remove the Company as the consumer’s agent
                                            of record; only the consumer possesses the right to do so. Further, the Company owns the
                                            sole right to solicit its customers for other policies, products, and services, including
                                            following the cancellation or non-renewal of the policy and the termination of the carrier
                                            agreement.

 o In negotiations of carrier agreements,
                                            the Company is transparent with carriers that its business is focused on identifying the
                                            best policy for

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the end cons