July 2, 2019

Sean E. Quinn
Chief Financial Officer
Cimpress N.V.
Building D, Xerox Technology Park
Dundalk, Co. Louth
Ireland

       Re: Cimpress N.V.
           Form 10-K for the Fiscal Year Ended June 30, 2018
           Filed August 10, 2018
           Form 10-Q for the Quarterly Period Ended March 31, 2019
           Filed May 2, 2019
           File No. 000-51539

Dear Mr. Quinn:

       We have limited our review of your filing 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 for the Fiscal Year Ended June 30, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Additional Non-GAAP Financial Measures, page 44

1.    Refer to your discussion of free cash flow. As your computation differs
from the typical
      calculation of free cash flow (i.e., cash flows from operating activities
less capital
      expenditures), please revise your computation or revise the title of this
non-GAAP
      measure so it is not confused with free cash flow as typically
calculated, such as adjusted
      free cash flow. Also expand the narrative to disclose this measure does
not represent
      residual cash flow available for discretionary expenditures. Refer to
Item 10(e)(1)(i) of
      Regulation S-K and Question No. 102.07 of the Staff's Compliance &
Disclosure
      Interpretations ("C&DIs") of Non-GAAP Financial Measures, updated April
4, 2018.
 Sean E. Quinn
Cimpress N.V.
July 2, 2019
Page 2


Form 10-Q for the Quarterly Period Ended March 31, 2019

Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page 8

2.       Please tell us what consideration you gave to whether revenue from
your customized
         manufactured products should be recognized over time. Reference ASC
606-10-25-27(c).
3.       Please disclose whether any obligations for returns or refunds exist
and, if so, explain the
         nature of them. Reference ASC 606-10-50-12(d).
4.       Based on your disclosure it appears you have concluded that shipping
services are a
         separate performance obligation. Please tell us how you determined
that shipping revenue
         should be recognized when control of the related products is
transferred to your customer.
         Reference ASC 606-10-25-18B.


       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 Beverly Singleton at (202) 551-3328 or Andrew Mew at
(202) 551-
3377 with any questions.



FirstName LastNameSean E. Quinn                                Sincerely,
Comapany NameCimpress N.V.
                                                               Division of
Corporation Finance
July 2, 2019 Page 2                                            Office of
Transportation and Leisure
FirstName LastName