United States securities and exchange commission logo

                            April 18, 2022

       Trevor Bezkdek
       Co-Chief Executive Officer
       GoodRx Holdings, Inc.
       2701 Olympic Boulevard
       Santa Monica, CA 90404

                                                        Re: GoodRx Holdings,
                                                            Form 10-K For the
Fiscal Year Ended December 31, 2021
                                                            10-K filed March 1,
                                                            File No. 001-39549

       Dear Mr. Bezkdek:

              We have reviewed your filing 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

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K For the Fiscal Year Ended December 31, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Non-GAAP Financial Measures, page 61

   1.                                                   We note you discuss the
fluctuation in Adjusted EBITDA Margin without providing a
                                                        margin analysis for Net
Income, the most directly comparable GAAP financial measure.
                                                        Please disclose and
discuss Net Income Margin with equal or greater prominence to
                                                        Adjusted EBITDA Margin.
We refer to guidance in Question 102.10 of the Non-GAAP
                                                        Financial Measures
Compliance and Disclosure Interpretations. Please also consider this
                                                        comment as it applies
to your earnings releases filed on Form 8-K.
       Results of Operations, page 64

   2.                                                   In order to give
investors more insight into why prescription transaction revenue
                                                        increased, please
disclose the underlying reasons for the increase in monthly active
                                                        customers. For example,
what portion of the growth is related to acquisitions versus
 Trevor Bezkdek
GoodRx Holdings, Inc.
April 18, 2022
Page 2
         organic growth. Discuss the reason for any organic growth if
applicable. Also, since
         you discuss contribution-per-customer in your results of operations,
please disclose this
         metric and how it is calculated in your Key Financial and Operating
Metrics. We refer to
         guidance in Item 303 of Regulation S-K.
Notes to Consolidated Financial Statements
14. Stockholders Equity
Restricted Stock Units for Class B Common Stock, page F-29

3.       Tell us why the issuance of your RSUs is deferred by three-years from
the applicable
         vesting date.
        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.

        You may contact Inessa Kessman, Senior Staff Accountant at 202-551-3371
or Robert
Littlepage, Accounting Branch Chief at 202-551-3361 if you have questions
regarding comments
on the financial statements and related matters.

FirstName LastNameTrevor Bezkdek                             Sincerely,
Comapany NameGoodRx Holdings, Inc.
                                                             Division of
Corporation Finance
April 18, 2022 Page 2                                        Office of
FirstName LastName