United States securities and exchange commission logo

                     May 18, 2020

       David T. Pearson
       Chief Financial Officer
       Vonage Holdings Corp.
       23 Main Street
       Holmdel, NJ 07733

                                                        Re: Vonage Holdings
                                                            Form 10-K for
Fiscal Year Ended December 31, 2019
                                                            Filed February 21,
                                                            Form 8-K
                                                            Filed February 18,
                                                            File No. 001-32887

       Dear Mr. Pearson:

              We have completed our review of your filings. 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.


                     Division of Corporation Finance

                     Office of Technology