February 4, 2020

Dean Hager
Chief Executive Officer
Juno Topco, Inc.
100 Washington Ave S, Suite 1100
Minneapolis, MN 55401

       Re: Juno Topco, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted January 23, 2020
           CIK No. 0001721947

Dear Mr. Hager:

      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 response.

       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
comments. Unless otherwise noted, where prior comments are referred to they
refer to our letter
dated January 15, 2020.

Amendment No. 1 to Draft Registration Statement on Form S-1

Prospectus Summary
Industry Background, page 2

1.     We note your response to prior comment 1 that the company's entire
business is driven by
       and dependent upon the adoption of Apple products. However, there
appears to be no
       assurance that an increase in the adoption of Apple devices will lead to
an increase in
       sales of your software given that you do not have any exclusive
agreements or
       arrangements with Apple, either as a customer or as a channel partner.
Please disclose this
       risk in the prospectus summary and as a separate risk factor.
 Dean Hager
FirstName LastNameDean Hager
Juno Topco, Inc.
Comapany NameJuno Topco, Inc.
February 4, 2020
Page 2
February 4, 2020 Page 2
FirstName LastName
Our Relationship with Apple, page 6

2.       We note your response to prior comment 2 that Apple does not
materially contribute to
         your revenues either as a customer or as a channel partner. Please
balance your discussion
         regarding your relationship with Apple by disclosing that Apple
accounted for less than
         1% of the company's total revenue as a customer in fiscal year 2018
and represented
         approximately 9% of bookings as a channel partner in fiscal year 2018.
Selected Consolidated Financial Data
Non-GAAP Financial Measures, page 74

3.       We note your revised disclosure in response to prior comment 5. Please
further revise to
         state that while the amortization expense of acquired developed
technology is excluded,
         the related revenue is reflected in the measure as those assets
contribute to revenue
         generation.
       You may contact Melissa Kindelan, Senior Staff Accountant, at (202)
551-3564
or Christine Dietz, Senior Staff Accountant, at 202-551-3408 if you have
questions
regarding comments on the financial statements and related matters. Please
contact Jeff Kauten,
Staff Attorney, at (202) 551-3447 or Jan Woo, Legal Branch Chief, at (202)
551-3453 with any
other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Technology
cc:      Alexander M. Schwartz