United States securities and exchange commission logo

                              May 7, 2021

       David S. Rosenblatt
       Chief Executive Officer
       1stdibs.com, Inc.
       51 Astor Place, 3rd Floor
       New York, New York 10003

                                                        Re: 1stdibs.com, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted March 29,
                                                            CIK No. 0001600641

       Dear Mr. Rosenblatt:

             We have reviewed your amended 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

       Amendment No. 2 to Draft Registration Statement of Form S-1

       Key Factors Affecting Our Performance
       Sourcing and Quality of Our Highly-Curated Luxury Supply, page 69

   1.                                                   We note your response
to comment 3 that "the GMV retention rate has remained above
                                                        100% in each cohort and
that this has been the case for all cohorts since the Registrant
                                                        launched its e-commerce
site in 2013." To provide context for the average seller retention
                                                        rate for the 2015
through 2019 cohorts, please amend your disclosure to inform investors
                                                        that each of the years
presented in your table do not necessarily include data for all of the
                                                        cohorts in the 2015
through 2019 average. Please also disclose that the retention rate for
                                                        each cohort has
remained above 100% for each cohort separately, as you assert in your
Alternatively, please break out the data separately for each cohort.
 David S. Rosenblatt
1stdibs.com, Inc.
May 7, 2021
Page 2
Buyer Acquisition Costs and Lifetime Value, page 71

2.    We note your response to comment 4, and your amended disclosure on pages
73 and 74.
      Please amend your disclosure to briefly describe how you calculate and
allocate retention
      marketing costs to your buyer cohorts. Further, please amend your graphic
on page 72 to
      label your y axis to reflect the number of new active buyers shown.
       You may contact Patrick Kuhn at 202-551-3308 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Katherine Bagley at 202-551-2545 or Erin Jaskot at 202-551-3442 with
any other

FirstName LastNameDavid S. Rosenblatt
                                                           Division of
Corporation Finance
Comapany Name1stdibs.com, Inc.
                                                           Office of Trade &
May 7, 2021 Page 2
cc:       Davina K. Kaile
FirstName LastName