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                                                            February 21, 2025

Sean E. Quinn
Chief Financial Officer
Cimpress plc
First Floor Building 3
Finnabair Business and Technology Park A91 XR61
Dundalk, Co. Louth, Ireland

       Re: Cimpress plc
           Form 10-K for the Fiscal Year Ended June 30, 2024
           Filed August 9, 2024
           Form 8-K Furnished January 29, 2025
           File No. 001-39148
Dear Sean E. Quinn:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
 February 21, 2025
Page 2
Form 10-K for the Fiscal Year Ended June 30, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Consolidated Results of Operations, page 30

1.     Where you describe two or more business reasons that contributed to a
material
       change in a financial statement line item between periods, please
quantify, where
       possible, the extent to which each factor contributed to the overall
change in that line
       item, including any offsetting factors. In addition, where you identify
intermediate
       causes of changes in your operating results, also describe the reasons
underlying the
       intermediate causes. We note your disclosures that the changes in
segment revenue
       and consolidated cost of revenue from fiscal year 2023 to fiscal year
2024 were due to
       various factors. To the extent possible, quantify the impact of each
contributing factor
       in dollars and/or percentage, expand on the reasons driving these
changes, and provide
       greater transparency into the material components and potential
variability of your
       segment revenue and consolidated cost of revenue.
Additional Non-GAAP Financial Measures, page 39

2.     We note your reconciliation of the non-GAAP financial measure, adjusted
EBITDA,
       uses operating income as the starting point for reconciling the adjusted
EBITDA.
       Please refer to Question 103.02 of the Staff's Compliance and Disclosure
       Interpretation on Non-GAAP Financial Measures ("Non-GAAP C&DIs") and
modify
       your reconciliations in future filings accordingly. The comment also
applies to your
       earnings releases and other public disclosures, such as investor
presentations.
3.     We also note that the bullet points at the top of page 29 disclose
adjusted EBITDA
       without presenting the most directly comparable GAAP measure with equal
or greater
       prominence. Please confirm net income (loss) is the most directly
comparable GAAP
       measure and present it with equal or greater prominence in future
filings. Refer to
       Item 10(e)(1)(i)(A) of Regulation S-K and Questions 102.10(a) and 103.02
of the
       Non-GAAP C&DIs. The comment also applies to your earnings releases.
Notes to the Audited Financial Statements
Note 13. Income Taxes , page 82

4.     We note your disclosure that in 2024 you recognized a tax benefit of $
105,765 on the
       partial release of the valuation allowance in Switzerland as compared to
tax expense
       of $ 116,694 in the year ended June 30, 2023 to increase the valuation
allowance in
       Switzerland. We further note your disclosure that after considering all
available
       evidence, including the recent history of strong earnings from core
operations in
       Switzerland and the expectation of future taxable income, management
concluded it is
       more likely than not that the recognized deferred tax assets are
realizable and reduced
       the valuation allowance accordingly. Please explain to us in further
detail why you
       believe it was appropriate to increase the valuation allowance in 2023
only to release
       most of the balance during 2024.
Form 8-K Furnished January 29, 2025
 February 21, 2025
Page 3

Exhibit 99.1, page 7

5.     Although we note that EBITDA at the segment level represents a required
ASC
       280 measure, please note that the measure on a total combined basis
represents a non-
       GAAP measure. Accordingly, if you continue to present such measure
outside of your
       consolidated financial statements, such as your disclosure on page 7 of
your earnings
       release, please label it as a non-GAAP financial measure and ensure that
your
       presentation and disclosures comply with non-GAAP rules, including
       Item 10(e) of Regulation S-K and the Non-GAAP C&DI's. Please note, for
example,
       that the measure generally should not exclude normal, recurring, cash
operating
       expenses necessary to operate your business.
6.     We note your disclosure of adjusted EBITDA margin before you present and
discuss
       the most directly comparable GAAP measure. Please ensure you present the
most
       directly comparable GAAP measure with equal or greater prominence as
required by
       Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the
Non-GAAP
       C&DI's.
7.     We note your disclosures of contribution profit and contribution margin
on page 9 and
       net leverage ratios on page 11, which appear to be non-GAAP measures.
Please
       ensure that your presentation and disclosures comply with non-GAAP
rules, including
       Item 10(e) of Regulation S-K and the Non-GAAP C&DI's.
        In closing, 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.

       Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at
202-551-3301
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing
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