September 20, 2019

David Schlanger
Chief Executive Officer
Progyny, Inc.
245 5th Avenue
New York, New York 10016

       Re: Progyny, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted on September 11, 2019
           CIK No. 0001551306

Dear Mr. Schlanger :

      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.

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

The Offering, page 15

1.     Please revise the disclosure in this section to be as of the same date
as the common stock
       outstanding as disclosed in the principal and selling stockholders
information on page
       131. Similarly revise disclosure beginning on 134.
Our Clients, page 103

2.     We note your response to prior comment 6 regarding your customers;
however, it is
       unclear how you concluded that the identity of your principal customers,
including a
       customer who represented 17% of your business in the first six months of
2019 is not
       material. We note Item 101(c)(vii) requires a registrant to identify
customers if sales
 David Schlanger
Progyny, Inc.
September 20, 2019
Page 2
      equal 10 percent or more and the loss of such customer would have a
material adverse
      effect. Please provide an expanded analysis that explains clearly your
conclusion that the
      loss of such customers would not have a material adverse effect, or
disclose the names of
      such customers. We note your risk factor disclosure on page 23 regarding
the loss of such
      customers.
Executive Compensation, page 116

3.    We note your revisions in response to prior comment 8. Please further
revise your
      disclosure to describe clearly the material terms of the merit based
discretionary
      bonus awards made to named executives during the last completed fiscal
year, including a
      general description of the formula or criteria to be applied in
determining the amounts
      payable. See Item 402(o) of Regulation S-K.
      You may contact Ruairi Regan at 202-551-3269 or Pamela Howell, Special
Counsel, at
202-551-3357 if you have any questions.



                                                           Sincerely,

FirstName LastNameDavid Schlanger                          Division of
Corporation Finance
                                                           Office of Beverages,
Apparel and
Comapany NameProgyny, Inc.
                                                           Mining
September 20, 2019 Page 2
cc:       Alison Haggerty, Esq.
FirstName LastName