United States securities and exchange commission logo February 23, 2023 Jason Trevisan Chief Executive Officer CarGurus, Inc. 2 Canal Park 4th Floor Cambridge, MA 02141 Re: CarGurus, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 25, 2022 File No. 001-38233 Dear Jason Trevisan: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology cc: Javier Zamora