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 Corp. Form 10-K for Fiscal Year Ended December 31, 2019 Filed February 21, 2020 Form 8-K Filed February 18, 2020 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. Sincerely, Division of Corporation Finance Office of Technology