SecProbe.io

August 22, 2024
James C. Malone
Chief Financial Officer
Consensus Cloud Solutions, Inc.
700 S. Flower Street, 15th Floor
Los Angeles, California 90017
Re:Consensus Cloud Solutions, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-40750
Dear James C. Malone:
            We have reviewed your August 16, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our August 5, 2024 letter.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Performance Metrics, page 39
1.You state in your response to prior comment 1 that you have "contracts both initiated and
terminated ("lost") on a daily basis." Please clarify separately for both Corporate and
SoHo customers whether the same customer can both initiate and terminate a contract
within the same month and if so, tell us how often this typically happens. If not, explain
further how your reference to initiating and terminating contracts on a daily basis supports
the use of average customers in your calculation of churn. In addition, your disclosures
state that churn is calculated monthly and expressed as an average over the applicable
period. Tell us what the applicable period means in this context and how the average for
the period is calculated. Revise your disclosures as necessary to clarify your calculations.

August 22, 2024
Page 2
Notes to Consolidated Financial Statements
Note 3. Revenues, page 65
2.We note your response to prior comment 2. So that we may better assess your response
and disclosures, as previously requested, please provide us with the amount of usage fees
recognized for each period presented. Tell us what the performance obligations are for the
arrangements that include usage-based fees. In this regard, your response indicates that
your cloud-based services generally include a single performance obligation to stand
ready to process customer transactions, and your proposed revised disclosures refer to
allocating the transaction price to each performance obligation. In addition, explain
further how your proposed disclosures specifically address variable consideration
associated with the usage-based fee arrangements or revise further as necessary.
3.You disclose that you expect to recognize revenue from Corporate contracts in a range of
month-to-month up to 36 months and from SoHo contracts in a range from month-to-
month up to one year. Please tell us the terms of your contracts for both Corporate and
SoHo customers. Also, explain and revise to disclose whether your Corporate and SoHo
contracts include cancellation provisions, and if so, whether customers are subject to
penalties upon early termination.
            Please contact Dave Edgar at 202-551-3459 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Vithya Aubee