March 24, 2025

Allison Swartz
General Counsel
Progyny, Inc.
1359 Broadway
New York, NY 10018

       Re: Progyny, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2024
           File No. 001-39100
Dear Allison Swartz:

         We have reviewed your filing 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.

Form 10-K for the Fiscal Year Ended December 31, 2024
Financial Statements
Note 2. Revenue Recognition, page 71

1.     Your disclosure indicates that the sources of consideration from your
revenue
       contracts are all variable. Please expand your disclosures to state how
you estimate the
       variable consideration, and whether the estimate is constrained. Refer
to ASC 606-10-
       25-2(e) and 606-10-32. Tell us how you determined that it was probable
that you will
       collect substantially all of the consideration to which you are entitled
under your
       revenue contracts. See ASC 606-10-55-3A through 55-3. Finally, provide
the
       disclosures required by ASC 606-10-50-17 and 50-20.
Note 2. Accounts Receivable and Allowance for Doubtful Accounts, page 73

2.     We note that your allowance for doubtful accounts is material in
relation to your
       accounts receivable balance. Tell us and revise your disclosures to
address the
       estimates and assumptions underlying your determination of the allowance
as well as
       your write-off policy. Identify the point in time at which you (i)
provide an allowance
       and (ii) write off a receivable, including the extent to which your
allowance and write-
       offs are made on a specific versus general basis. Given your allowance
for doubtful
       accounts represents approximately 20% of your gross accounts receivable
balance,
 March 24, 2025
Page 2

       please revise your disclosures to explain the underlying factors that
result in the
       allowance, including whether potential collectability issues associated
with your
       accounts receivable are due to the nature of your customers, the nature
of your
       products or other factors.
        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. Please contact Al Pavot at 202-551-3738 or Jeanne Baker
at 202-551-
3691 if you have questions regarding comments on the financial statements and
related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Industrial Applications and
                                                             Services