United States securities and exchange commission logo

                 June 29, 2020

       Paris Cavic
       Vice President and General Counsel
       Benefitfocus, Inc.
       100 Benefitfocus Way
       Charleston, South Carolina 29492

                                                        Re: Benefitfocus, Inc.
Statement on Form S-3
                                                            Filed June 24, 2020
                                                            File No. 333-239406

       Dear Mr. Cavic:

              This is to advise you that we have not reviewed and will not
review your registration

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Matthew Crispino, Staff Attorney, at (202) 551-3456
or Jan Woo, Legal
       Branch Chief, at (202) 551-3453 with any questions.


                 Division of Corporation Finance

                 Office of Technology
       cc:                                              Andrew J. Gibbons, Esq.