United States securities and exchange commission logo

                            September 18, 2020

       Trevor Bezdek
       Co-Chief Executive Officer
       GoodRx Holdings, Inc.
       233 Wilshire Blvd., Suite 990
       Santa Monica, CA 90401

                                                        Re: GoodRx Holdings,
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed September 14,
                                                            File No. 333-248465

       Dear Mr. Bezdek:

             We have reviewed your amended registration statement and have the
       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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 10, 2020 letter.

       Registration Statement on Form S-1 filed September 14, 2020

       10. Subsequent Events
       Events Subsequent to Date the Condensed Consolidated Financial
Statements Were Available to
       Be Issued, page F-48

   1.                                                   We note the disclosure
beginning on page 155. Please disclose the facts and
                                                        circumstances of IPO
Awards including the material terms, fair value, and the anticipated
                                                        timing and amount of
the compensation expense expected to be incurred.
 Trevor Bezdek
FirstName LastNameTrevor  Bezdek
GoodRx Holdings,  Inc.
Comapany 18,
September NameGoodRx
              2020      Holdings, Inc.
Page 2    18, 2020 Page 2
FirstName LastName
        You may contact Kathryn Jacobson, Staff Accountant, at (202) 551-3365
or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
comments on the financial statements and related matters. Please contact
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other


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cc:      Benjamin J. Cohen