United States securities and exchange commission logo

                            February 12, 2021

       Ashish Arora
       Chief Executive Officer and Director
       Cricut, Inc.
       10855 South River Front Parkway
       South Jordan, Utah 84095

                                                        Re: Cricut, Inc.
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted February
1, 2021
                                                            CIK No. 0001828962

       Dear Mr. Arora:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form S-1

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Quarterly Results of Operations and Key Metrics
       Quarterly Results of Operations, page 97

   1.                                                   Your disclosure on page
99 indicates that the number of users increased 12% as of
                                                        September 30, 2020 as
compared to June 30, 2020. However, your connected machine
                                                        revenue decreased 33%
during this period. Please clarify the reason for this and if there
                                                        any trends impacting
revenue growth, or trends impacting growth in users as compared to
                                                        growth in connected
machine revenue.
 Ashish Arora
Cricut, Inc.LastNameAshish Arora
February    NameCricut,
              2021      Inc.
Page 2 12, 2021 Page 2
FirstName LastName
Consolidated Financial Statements
Notes to Consolidated Financial Statements
11. Stock Based Compensation, page F-27

2.       When your preliminary IPO price is known, please reconcile and explain
the differences
         between the fair values of the underlying equity interest determined
on each grant date
         including the difference between the most recent grant date fair value
and the midpoint of
         your offering range. Describe the objective evidence that supports
your determination of
         the fair value of the underlying equity interest at each grant or
issue date. Please provide
         this analysis for the most recent six months. In addition, your
disclosure should fully
         describe the assumptions utilized at the IPO valuation date that are
significantly different
         than those used in the most recent valuation.
       You may contact Laura Veator, Staff Accountant, at (202) 551-3716 or
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
comments on the financial statements and related matters. Please contact
Matthew Crispino,
Staff Attorney, at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202)
551-3453 with any
other questions.


                                                               Division of
Corporation Finance
                                                               Office of
cc:      Rezwan D. Pavri