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                           August 11, 2022

       David Morken
       Chief Executive Officer
       Bandwidth Inc.
       900 Main Campus Drive
       Raleigh, NC 27606

                                                        Re: Bandwidth Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed on February
25, 2022
                                                            File No. 001-38285

       Dear Mr. Morken:

              We have reviewed your August 9, 2022 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
       July 28, 2022 letter.

       Form 10-K for the Year Ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 76

   1.                                                   You state in your
response to prior comment 1 that for non-GAAP purposes the company
                                                        was in a cumulative
pre-tax income position in the U.S. from 2019     2021. However, you
                                                        also indicate that
given the company   s historical and forecasted non-GAAP loss positions
                                                        you concluded that a
valuation allowance was appropriate in the U.S. for non-GAAP
                                                        purposes. Please
explain these apparent inconsistencies. Also, explain further the non-
                                                        GAAP tax attributes
that were used to offset non-GAAP pre-tax income and when such
                                                        amounts will be fully
utilized.
 David Morken
FirstName
Bandwidth LastNameDavid  Morken
           Inc.
Comapany
August 11, NameBandwidth
           2022          Inc.
August
Page 2 11, 2022 Page 2
FirstName LastName
2.       The calculations for the effective tax rate provided in your response
are based on the non-
         GAAP tax adjustment as a percentage of the individual non-GAAP
adjustments. Please
         provide us with your calculation of the non-GAAP effective tax rate
using the total tax
         provision (benefit) on a non-GAAP basis to total non-GAAP pre-tax
income (loss) and
         revise to disclose such rates in the footnotes to your non-GAAP
reconciliations to the
         extent they differ from amounts already disclosed. Also, explain how
you determined
         whether the non-GAAP income tax expense is commensurate with the
non-GAAP
         measure of profitability. Refer to Question 102.09 of the non-GAAP
C&DIs.
       You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology