July 25, 2024

Tim Cabral
Chief Financial Officer
Veeva Systems Inc.
4280 Hacienda Drive
Pleasanton, CA 94588

        Re: Veeva Systems Inc.
            Form 10-K for the Fiscal Year Ended January 31, 2024
Dear Tim Cabral:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 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.

Form 10-K for the Period Ended January 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Opertions
Revenues, page 41

1.     Please expand your discussion to fully describe and analyze the
underlying business
       reasons for material changes in revenues. Please discuss and quantify
the effects of
       changes in both price and volume on revenues, where appropriate. For
example, please
       explain why subscription services revenues attributable to R&D Solutions
and
       Commercial Solutions increased $119 million and $50 million,
respectively, in the year
       ended January 31, 2024. In addition, while applicable please describe
the change in the
       timing of revenue recognition resulting from the addition of termination
for convenience
       rights in your master subscription agreements beginning February 1, 2023
and quantify
       the impact on revenue recognition. Refer to Item 303(b) of Regulation
S-K.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
 July 25, 2024
Page 2



      Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-551-
3361 with any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Technology