United States securities and exchange commission logo

                             March 9, 2021

       Gleb Budman
       Chief Executive Officer
       Backblaze, Inc.
       500 Ben Franklin Ct.
       San Mateo, CA 94401

                                                        Re: Backblaze, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted February
10, 2021
                                                            CIK No. 0001462056

       Dear Mr. Budman:

              We have reviewed your draft registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form S-1

       Key Business Metrics, page 56

   1.                                                   You disclose that your
business and future success depends in part on your ability to add
                                                        new customers and to
increase usage and adoption of your solutions with existing
                                                        customers. Please tell
us what consideration was given in disclosing the number of new
                                                        and existing customers
for the periods presented. We refer you to Section III.B of SEC
                                                        Release No. 33-8350.
 Gleb Budman
Backblaze, LastNameGleb Budman
March      NameBackblaze, Inc.
       9, 2021
March2 9, 2021 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Critical Accounting Policies and Estimates
Revenue Recognition, page 65

2.       You disclose that revenue from consumption-based arrangements are
recognized upon
         invoice. Please clarify whether your invoice is within the same period
that the service
         revenue was earned. That is, revenue is being recognized when
3.       Please tell us how you concluded that your arrangements do not include
a software
         license. We refer you to ASC 985-605-55-119 to 55-125. In addition,
please tell us
         whether you incur set up costs and charge an installation fee for new
Common Stock Valuations, page 66

4.       When your preliminary IPO price is known, please reconcile and explain
the differences
         between the fair values of the underlying equity interest determined
on each grant date,
         including the difference between the most recent grant date fair value
and the midpoint of
         your offering range. Describe the objective evidence that supports
your determination of
         the fair value of the underlying equity interest at each grant or
issue date. Please provide
         this analysis for the one year period preceding the filing of the
draft registration
         statement. In addition, your disclosure should fully describe the
assumptions utilized at
         the IPO valuation date that are significantly different than those
used in the most recent
Principal Stockholders, page 101

5.       Please disclose the natural person or persons who exercise the voting
         dispositive powers with respect to the securities owned by TMT
Investments PLC.
Description of Capital Stock
Choice of Forum, page 108

6.       Please disclose whether the exclusive forum provision in your
certificate of incorporation
         applies to actions arising under the Securities Act. Section 22 of the
Securities Act creates
         concurrent jurisdiction for federal and state courts over all suits
brought to enforce any
         duty or liability created by the Securities Act or the rules and
regulations thereunder. If
         the provision applies to Securities Act claims, please clearly
describe the provision in your
         disclosure including any risks to investors related to the provision.
Please also state that
         there is uncertainty as to whether a court would enforce such
provision and that investors
         cannot waive compliance with the federal securities laws and the rules
and regulations
 Gleb Budman
Backblaze, Inc.
March 9, 2021
Page 3

7.    Please supplementally provide us with copies of all written
communications, as defined in
      Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
      present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
      not they retain copies of the communications.
       You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
comments on the financial statements and related matters. Please contact
Michael C.
Foland, Attorney-Advisor, at (202) 551-6711 or Jan Woo, Legal Branch Chief, at
(202) 551-
3453 with any other questions.

FirstName LastNameGleb Budman
                                                            Division of
Corporation Finance
Comapany NameBackblaze, Inc.
                                                            Office of
March 9, 2021 Page 3
cc:       Bennett L. Yee
FirstName LastName