July 24, 2025

Jennifer DiRico
Chief Financial Officer
Commvault Systems, Inc.
1 Commvault Way
Tinton Falls, New Jersey 07724

       Re: Commvault Systems, Inc.
           Form 10-K for the Fiscal Year Ended March 31, 2025
           Response dated July 2, 2025
           File No. 001-33026
Dear Jennifer DiRico:

       We have reviewed your July 2, 2025 response to our comment letter and
have the
following comment.

       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 the
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 June 17,
2025 letter.

Form 10-K for the Year Ended March 31, 2025
Consolidated Statements of Operations, page 47

1.     We have reviewed your responses to our prior comments 3 and 4 and have
the
       following additional comments:
           It appears that revenue generated from perpetual and term software
licenses is
           greater than ten percent of total revenues. Therefore, it continues
to be unclear to
           us why you have not separately presented this amount as product
revenue on the
           face of your consolidated statements of operations in accordance
with Rule 5-
           03(b) of Regulation S-X.
           We note you have concluded that your subscription arrangements have
term-
           based licenses and SaaS offerings that are treated as separate
performance
           obligations. We further note that the term-based licenses are
recognized when the
           software is delivered or made available for download and the SaaS is
generally
 July 24, 2025
Page 2

           recognized ratably over the contract term beginning on the date the
service is
           made available to the customer. However, you have not disclosed the
amounts
           recognized in revenue related to these offerings. It is unclear to
us how you have
           considered ASC 606-10-50-1.
           We note that you have not quantified and disclosed how revenue
recognized from
           your term-based licenses and SaaS offerings impacts your results of
operations. It
           is unclear to us how you have considered Item 303 of Regulation S-K.
       Please advise or revise your disclosures in future filings to address
these items.
       Please contact Chen Chen at 202-551-7351 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:   Danielle Sheer