August 28, 2025

Jennifer Hsu
Chief Financial Officer
Clear Secure, Inc.
85 10th Avenue, 9th Floor
New York, NY 10011

       Re: Clear Secure, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2024
           File No. 001-40568
Dear Jennifer Hsu:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Financial Statements
Consolidated Balance Sheet, page 67

1.     We note a related party exchanged 4,000,000 of their Alclear Units and
corresponding
       shares of Class C Common Stock for shares of the Company   s Class A
Common
       Stock, and the Company repurchased and retired the shares of Class A
Common
       Stock. Please provide us a chronological summary of all such instances
where Alclear
       Units along with the corresponding shares Class C Common Stock or Class
D
       Common Stock were exchanged for shares of your Class A Common Stock or
Class B
       Common Stock. Indicate if the issued Class A or Class B shares were
repurchased and
       retired by the Company and if so, tell us if the repurchases were funded
with cash
       raised in a public offering or private sale of Class A Common Stock. In
the absence of
       a concurrent public offering or private sale of Class A Common Stock,
tell us how the
       repurchases were made in accordance with the terms of the Exchange
Agreement.
       Also, please tell us why you do not report the Alclear Units, Class C
Common Stock
       and Class D Common Stock as temporary equity and explain to us your
consideration
       of the guidance in ASC 480-10-S99-3A and specifically, example 2 of this
guidance.
 August 28, 2025
Page 2

        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.

      Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-
551-3361 with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology