August 22, 2024

James C. Malone
Chief Financial Officer
Consensus Cloud Solutions, Inc.
700 S. Flower Street, 15th Floor
Los Angeles, California 90017

       Re: Consensus Cloud Solutions, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           File No. 001-40750
Dear James C. Malone:

       We have reviewed your August 16, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our August
5, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Performance Metrics, page 39

1.     You state in your response to prior comment 1 that you have "contracts
both initiated and
       terminated ("lost") on a daily basis." Please clarify separately for
both Corporate and
       SoHo customers whether the same customer can both initiate and terminate
a contract
       within the same month and if so, tell us how often this typically
happens. If not, explain
       further how your reference to initiating and terminating contracts on a
daily basis supports
       the use of average customers in your calculation of churn. In addition,
your disclosures
       state that churn is calculated monthly and expressed as an average over
the applicable
       period. Tell us what the applicable period means in this context and how
the average for
       the period is calculated. Revise your disclosures as necessary to
clarify your calculations.
 August 22, 2024
Page 2
Notes to Consolidated Financial Statements
Note 3. Revenues, page 65

2.     We note your response to prior comment 2. So that we may better assess
your response
       and disclosures, as previously requested, please provide us with the
amount of usage fees
       recognized for each period presented. Tell us what the performance
obligations are for the
       arrangements that include usage-based fees. In this regard, your
response indicates that
       your cloud-based services generally include a single performance
obligation to stand
       ready to process customer transactions, and your proposed revised
disclosures refer to
       allocating the transaction price to each performance obligation. In
addition, explain
       further how your proposed disclosures specifically address variable
consideration
       associated with the usage-based fee arrangements or revise further as
necessary.
3.     You disclose that you expect to recognize revenue from Corporate
contracts in a range of
       month-to-month up to 36 months and from SoHo contracts in a range from
month-to-
       month up to one year. Please tell us the terms of your contracts for
both Corporate and
       SoHo customers. Also, explain and revise to disclose whether your
Corporate and SoHo
       contracts include cancellation provisions, and if so, whether customers
are subject to
       penalties upon early termination.

       Please contact Dave Edgar at 202-551-3459 or Kathleen Collins at
202-551-3499 if you
have questions regarding comments on the financial statements and related
matters.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:   Vithya Aubee