February 24, 2025

Sandeep Sahai
Chief Executive Officer
Clearwater Analytics Holdings, Inc.
777 W. Main Street
Suite 900
Boise, ID

       Re: Clearwater Analytics Holdings, Inc.
           Registration Statement on Form S-4
           Filed February 11, 2025
           File No. 333-284816
Dear Sandeep Sahai:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-4
General

1.     Please revise the summary, risk factors or elsewhere in the forepart of
the registration
       statement to clarify:

             whether the Final Parent Stock Price will be known before the
Election Deadline;
             whether Enfusion has the right to terminate the transaction if
Clearwater's
           common stock price falls below a certain price (i.e., walk-away
rights) and, if so,
           Enfusion's intention regarding resolicitation if walk-away rights
are triggered and
           a discussion of the Enfusion board's fiduciary duties to its
shareholders with
           respect to such decision, including the factors the board will
consider in deciding
           whether to exercise its walk-away rights;
 February 24, 2025
Page 2

             an illustrative table using a reasonable range of prices of
Clearwater's common
           stock with columns indicating the respective exchange ratios and
other relevant
           information;
             if material, the volatility of Clearwater's common stock over a
recent historical
           period and any risks relating to the volatility;
             the time period anticipated between the vote and closing; and
             how the 10% collar is calculated.
2.     It appears that Enfusion stockholders will not make their cash/stock
election at the
       same time as their vote. Please advise us of the applicability of the
tender offer rules
       to the cash election.
3.     In order to better inform Enfusion stockholders on the value of the
stock consideration
       as part of their decision on how much stock versus cash to elect, please
consider
       providing these stockholders with a means of viewing the 10-Day Average
Clearwater
       Common Stock VWAP for each day from the date of mailing through the
Election
       Deadline.
Exhibits

4.     The exhibit index indicates that the Kirkland & Ellis tax opinion will
be filed. Please
       also file the Dechert tax opinion or advise.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Mitchell Austin at 202-551-3574 or Jan Woo at
202-551-3453 with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:   Ross Leff