July 7, 2025

Jeff Hoffmeister
Chief Financial Officer
Shopify, Inc.
151 O'Connor Street, Ground Floor
Ottawa, Ontario, Canada K2P 2L8

        Re: Shopify, Inc.
            Form 10-K for the year ended December 31, 2024
            File No. 001-37400
Dear Jeff Hoffmeister:

       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 ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Performance Indicators, page 48

1.     You state that your business model is driven by your ability to attract
new merchants,
       retain revenue from existing merchants, and increase sales to both new
and existing
       merchants. In addition, you believe your future success depends in part
on your ability
       to expand your merchant base. We note you previously provided a measure
of
       monthly billing retention rate that you used to evaluate your ability to
maintain and
       expand your relationships with merchants. Please clarify whether
management
       currently uses this measure or tell us what measures they now use to
monitor your
       ability to retain and grow your existing merchant base, and revise to
include a
       quantified discussion of such measures for each period presented. Refer
to SEC
       Release 33-10751.
 July 7, 2025
Page 2
2.     We note from your discussion of Monthly Recurring Revenue (MRR) you
analyze the
       factors that make up MRR, specifically the number of paying merchants
using your
       platform and changes in average revenue earned from subscription plan
fees per
       paying merchant. Please describe for us how management uses the number
of paying
       merchants in their analysis and tell us what consideration you gave to
including the
       number of paying merchants as a key performance indicator to evaluate
your business.
       In your response, provide us with the number of paying merchants for
each period
       presented.
Discussion of the Results of Operations, page 54

3.     We note fluctuations between periods in subscription revenue were due to
       various factors including a higher number of merchants using the
platform
       and increases in subscription pricing, and fluctuations in cost of
revenue for both
       subscriptions and merchant solutions were also due to a variety of
factors. In addition,
       we note your references to changes being due    primarily    or "mainly"
to these factors.
       Where a material change is attributed to two or more factors, including
any offsetting
       factors, please revise to describe the contribution of each factor in
quantified terms.
       Also, revise to use more definitive terminology, rather than general or
vague terms
       such as    primarily    and "mainly," to describe each contributing
factor. Refer to Item
       303(b) of Regulation S-K.
Notes to the Consolidated Financial Statements
Note 23. Segment and Geographical Information, page 116

4.     Please revise to disclose how the CODM uses the segment measure of
consolidated
       net income (loss) to manage segment performance and allocate resources.
Refer to
       ASC 280-10-50-29(f) and the example in 280-10-55-54(c).
5.     We note your subscription solutions include revenue from subscriptions
to the
       Shopify platform as well as from the sale of themes, apps and domain
names. We also
       note that merchant solutions revenue is principally generated from
payment
       processing and currency conversion fees, but also includes revenue from
third-party
       referral fees, sales of products such as shipping labels and POS
hardware, advertising
       and lending services. Please tell us your consideration to provide a
breakdown of
       revenue for each of the products and services included in subscription
solutions and
       merchant solutions. In your response, provide us with the amount of
revenue from
       each of the products and services included in these revenue line items.
Refer to ASC
       280-10-50-40.

        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 7, 2025
Page 3

       Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at
202-551-3499
with any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Technology
cc:   Jessica Hertz