August 18, 2025

Jennifer G. Tejada
Chief Executive Officer
PagerDuty, Inc.
600 Townsend St., Suite 200
San Francisco, California 94108

        Re: PagerDuty, Inc.
            Form 10-K for the Fiscal Year Ended January 31, 2025
            File No. 001-38856
Dear Jennifer G. Tejada:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 Year Ending January 31, 2025
Notes to the Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 77

1.     Please tell us whether the amount of license revenue recognized from the
term-license
       software subscriptions are greater than ten percent of total revenues.
If so, please tell
       us how you considered separately presenting this amount as product
revenue on the
       face of your consolidated statements of operations in accordance with
Rule 5-
       03(b)(1)(a) of Regulation S-X. In addition, we further note that the
term software
       licenses are recognized at a point in time while cloud-hosted software
subscriptions
       and software maintenance revenues are recognized ratably over the
related contractual
       term. In this regard, please describe how you have considered the
guidance in ASC
       606-10-50-1 in evaluating whether your disclosures should disaggregate
revenues.
       Lastly, please provide quantitative information and analysis of revenue
amounts
       attributable to term-based licenses and cloud-hosted software
subscriptions in your
       MD&A, or tell us why such disclosure is not necessary to provide
investors with an
       understanding of your results of operations. We refer you to Item 303(a)
and (b) of
 August 18, 2025
Page 2

       Regulation S-K. As part of your response, quantify the total amount of
term-based
       licenses and cloud-hosted solutions for each period presented.
Note 8. Leases, page 91

2.     You disclose that your leases do not provide an implicit rate and you
use an estimated
       incremental borrowing rate based on the information available at the
lease
       commencement date in determining the present value of lease payments.
Please revise
       your disclosure in future filings to clarify that the rates implicit in
your leases are not
       readily determinable and if that is the basis for using your incremental
borrowing rate
       as the discount rate for your leases. Refer to    Rate Implicit in the
Lease    defined in
       ASC 842-20-20.
Note 11. Deferred Revenue and Remaining Performance Obligations, page 96

3.     You disclose that the company expects to recognize revenue of
approximately
       $302 million, or 68.6%, over the next 12 months with the balance to be
recognized as
       revenue thereafter. Please revise to disclose when the remaining
percentages will be
       recognized on a quantitative basis using time bands that would be most
appropriate
       for the duration of the remaining performance obligations or by
providing qualitative
       information. Refer to ASC 606-10-50-13.
        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.

       Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology