United States securities and exchange commission logo

                            May 24, 2022

       Edward Durkin
       Chief Financial Officer
       Casa Systems, Inc.
       100 Old River Road
       Andover , Massachusetts 01810

                                                        Re: Casa Systems, Inc.
                                                            Form 10-K for the
year ended December 31, 2021
                                                            Form 8-K furnished
April 18, 2022
                                                            File No. 1-38324

       Dear Mr. Durkin:

              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 filed February 25, 2022

       Consolidated Statements of Operations and Comprehensive Income (Loss),
page 76

   1.                                                   We note from your
disclosure on page 59 of MD&A that the decrease in selling, general
                                                        and administrative
expense was primarily driven by a $2.5 million decrease in
                                                        depreciation expense as
assets that became fully depreciated were not replaced. Please
                                                        tell us if all
depreciation expense is included in selling, general and administrative
                                                        expense or if any
amounts are included in cost of revenue and tell us how you considered
                                                        the guidance in SAB
Topic 11:B. Please note that we believe it would be inappropriate to
                                                        present a gross profit
subtotal that excludes depreciation and amortization.

       Notes to Consolidated Financial Statements
       Summary of Significant Accounting Policies
       Inventories, page 80
 Edward Durkin
FirstName  LastNameEdward Durkin
Casa Systems, Inc.
May        NameCasa Systems, Inc.
     24, 2022
May 24,
Page 2 2022 Page 2
FirstName LastName

2.       You disclose that inventories are stated at the lower of cost or
market value. Please clarify
         if you recognize inventory at the lower of cost or market value, or
lower of cost or net
         realizable value, and revise your disclosures accordingly. See ASC
Notes to Consolidated Financial Statements
Summary of Significant Accounting Policies
Revenue Recognition, page 83

3.       Please clarify the nature of the maintenance and support services
provided to customers in
         connection with your perpetual licenses. If material, tell us how you
determined that these
         support services are distinct performance obligations. To better
understand your
         disclosure, tell us if customers can 'opt out' of support services
included in the original
         sale, for a discounted purchase price. Please also disclose the
percentage of customers
         who purchase the annual renewals. Refer to ASC 606-10-25-21.

Note 16. Segment Information, page 107

4.       We note from your disclosure in Note 16 that you operate as one
operating segment and
         the CODM is your President and Chief Executive Officer. We also note
from an Investor
         Day 2021 presentation, that management includes Vice Presidents of
Access Devices,
         Product Management and Wireline Solutions. Please describe the role of
the CODM and
         each of the individuals who report to the CODM. Also, please describe
the roles of the
         aforementioned Vice Presidents. In addition, please provide us the
following information:

                Tell us how often the CODM meets with his/her direct reports,
the financial
              information the CODM reviews to prepare for those meetings, the
              information discussed in those meetings, and who else attends
those meetings;
                Describe the information regularly provided to the CODM and how
frequently it is
                Describe the information regularly provided to the Board of
Directors and how
              frequently it is prepared;
                Explain how budgets are prepared, who approves the budget at
each step of the
              process, the level of detail discussed at each step, and the
level at which the CODM
              makes changes to the budget;
                Describe the level of detail communicated to the CODM when
actual results differ
              from budgets and who is involved in meetings with the CODM to
discuss budget-to-
              actual variances; and
                Describe the basis for determining the compensation for each of
the individuals that
              report to the CODM.
 Edward Durkin
Casa Systems, Inc.
May 24, 2022
Page 3
Form 8-K furnished April 18, 2022

Exhibit 99.1 Earnings Release
Reconciliation of Selected GAAP and Non-GAAP Financial Measures, page 7

5.       We note that your reconciliation of net income to non-GAAP net income
includes an
         adjustment for amortization of acquired intangibles. Please revise to
disclose the nature of
         the amortization that is being excluded from the measure; and that
while the expense is
         excluded, the revenue of the acquired company is reflected in the
measure and that those
         assets contribute to revenue generation.
       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 Charles Eastman at 202-551-3794 or Claire Erlanger at
3301 with any questions.

FirstName LastNameEdward Durkin                                Sincerely,
Comapany NameCasa Systems, Inc.
                                                               Division of
Corporation Finance
May 24, 2022 Page 3                                            Office of
FirstName LastName