United States securities and exchange commission logo September 10, 2021 Raul Villar Jr. Chief Executive Officer Paycor HCM, Inc. 4811 Montgomery Road Cincinnati, Ohio 45212 Re: Paycor HCM, Inc. Draft Registration Statement on Form S-1 Submitted September 3, 2021 CIK No. 0001839439 Dear Mr. Villar Jr.: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Robert E. Goedert, P.C.