July 23, 2024 Erica Gessert Chief Financial Officer Upwork Inc. 475 Brannan Street, Suite 430 San Francisco, CA 94107 Re: Upwork Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-38678 Dear Erica Gessert: 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: Brian Levey