October 16, 2018

David Clark
Chief Financial Officer
Synchronoss Technologies, Inc.
200 Crossing Boulevard
8th Floor
Bridgewater, New Jersey 08807

       Re: Synchronoss Technologies, Inc.
           Forms 10-K and 10-K/A for the year ended December 31, 2017
           Filed July 2, 2018, and July 9, 2018, respectively
           Forms 10-Q and 10-Q/A for the period ended March 31, 2018
           Filed July 2, 2018
           Form 10-Q for the period ended June 30, 2018
           Filed August 9, 2018
           File No. 000-52049

Dear Mr. Clark:

       We have limited our review of your filings to the financial statements
and related
disclosures 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 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/A for the fiscal year ended December 31, 2017

Note 3. Summary of Significant Accounting Policies
Segment and Geographic Information, page 130

1.    You state that Verizon accounted for more than 10% of your revenue in
fiscal 2017. Tell
      us and revise to disclose the amount of revenue generated from each
customer when such
      revenue exceeds 10% of total revenue. Refer to ASC 280-10-50-42.
 David Clark
FirstName LastNameDavid Inc.
Synchronoss Technologies, Clark
Comapany NameSynchronoss Technologies, Inc.
October 16, 2018
Page 2
October 16, 2018 Page 2
FirstName LastName
Note 8. Goodwill and Intangibles, page 144

2.       Please tell us how you considered the qualitative factors outlined in
ASC 350-20-35-3C
         when performing your goodwill impairment analysis and clarify whether
you performed a
         qualitative or quantitative assessment, or both. Also, tell us whether
any of your reporting
         units are at risk of failing a quantitative analysis and if true,
revise your critical accounting
         policies to disclose:

             The percentage by which fair value exceeded carrying value as of
the date of the most
             recent test;
             The amount of goodwill allocated to the reporting unit;
             A discussion of the degree of uncertainty, which includes
specifics to the extent
             possible, associated with key assumptions used in your analysis;
and
             A description of potential events and/or changes in circumstances
that could
             reasonably be expected to negatively affect the key assumptions.

         If you have determined that estimated fair values substantially exceed
the carrying values
         of your reporting units, please disclose such determination. Refer to
Item 303(a)(3)(ii) of
         Regulation S-K and Section V of SEC Release 33-8350.
Form 10-Q/A for the quarterly period ended March 31, 2018

Note 2. Basis of Presentation and Consolidation
Changes in accounting principles as a result of adopting Topic 606 and nature
of goods, page 11

3.       You state that when observable data is not available for certain
software licenses because
         there is a limited number of transactions or prices are highly
variable, you estimate the
         standalone selling price using the residual method. Please provide a
comprehensive,
         quantitative discussion of such variability to support your
conclusion.
4.       You refer to variable consideration related to your subscription
services. Please describe
         for us the variable consideration included in such arrangements and
revise to provide a
         description of the types of variable consideration related to each of
your service lines, as
         appropriate. Also address how you measure obligations for returns or
refunds, if
         applicable. Refer to the guidance in ASC 606-10-50-20.
Transaction price allocated to the remaining performance obligation, page 13

5.       Please revise to include a description of the variable consideration
that has been excluded
         from this disclosure, such as the nature of the variability and how
such variability will be
         resolved. Refer to guidance in ASC 606-10-50-15.
 David Clark
Synchronoss Technologies, Inc.
October 16, 2018
Page 3
Form 10-Q for the quarterly period ended June 30, 2018

Item 4. Controls and Procedures, page 49

6.       Please revise to disclose the conclusion of your principal executive
and principal financial
         officers regarding the effectiveness of your disclosure controls and
procedures as of the
         period covered by this report. Refer to Rule 307 of Regulation S-K.
7.       Please revise to disclose any change(s) in your internal control over
financial reporting
         identified that occurred during the fiscal quarter that has materially
affected, or is
         reasonably likely to materially affect, your internal control over
financial reporting. Refer
         to Rule 308 of Regulation S-K.
       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.

       You may contact Brittany Ebbertt, Senior Staff Accountant, at
202-551-3572 or
Kathleen Collins, Branch Chief, at 202-551-3499 with any questions.



                                                               Sincerely,
FirstName LastNameDavid Clark
                                                               Division of
Corporation Finance
Comapany NameSynchronoss Technologies, Inc.
                                                               Office of
Information Technologies
October 16, 2018 Page 3                                        and Services
FirstName LastName