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                                                            May 14, 2019

Sumit Singh
CEO
Chewy, Inc.
1855 Griffin Road, Suite B-428
Dania Beach, Florida 33004

       Re: Chewy, Inc.
           Registration Statement on Form S-1
           Filed April 29, 2019
           File No. 333-231095

Dear Mr. Singh:

       We have reviewed your 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 amending your registration statement
and providing the
requested information. 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
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Factors Affecting Our Performance
Efficiency of Spending on Advertising and Marketing, page 66

1.     We note your disclosure of lifetime value of customer (LTV) to customer
acquisition cost
       (CAC) ratios. Please tell us your consideration of the applicability of
the disclosure
       requirements in Item 10(e) of Regulation S-K with respect to your
presentation of these
       ratios. In this regard, we note that the computation of LTV is based on
cumulative
       contribution profit, which appears to be a non-GAAP measure of income.
2.     Enhance your disclosure to provide the amounts that underlie the ratios
you disclose. For
       example, provide the CAC and LTV amounts per customer, per period
represented.
 Sumit Singh
Chewy, Inc.
May 14, 2019
Page 2
Principal and Selling Stockholders, page 118

3.       We note your response to prior comment 10. Please revise your
disclosure to identify the
         members of the board of directors of Argos Holdings GP LLC. Please
also tell us why
         you have not disclosed that affiliates of BC Partners are beneficial
owners, given your
         disclosure elsewhere that such affiliates control Argos Holdings.
Certain Relationships and Related Party Transactions, page 129

4.       We note your response to Comment 11. Please confirm that you will
similarly update the
         disclosure for the Master Transaction Agreement.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Tatanisha Meadows at 202-551-3322 or Robyn Manuel at
202-551-
3823 if you have questions regarding comments on the financial statements and
related
matters. Please contact Charles Guidry at 202-551-3621 or Mara Ransom at
202-551-3264 with
any other questions.



FirstName LastNameSumit Singh                                Sincerely,
Comapany NameChewy, Inc.
                                                             Division of
Corporation Finance
May 14, 2019 Page 2                                          Office of Consumer
Products
FirstName LastName
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