October 26, 2018

Ethan Brown
President and Chief Executive Officer
Beyond Meat, Inc.
1325 E. El Segundo Blvd.
El Segundo, CA 90245

       Re: Beyond Meat, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted October 16, 2018
           CIK No. 0001655210

Dear Mr. Brown:

      We have reviewed your amended draft registration statement and have the
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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Our references to our prior comments are to comments in our letter of
October 9,

Amendment No. 1 to Draft Registration Statement on Form S-1

Business   The Beyond Meat Strategic Difference, page 73

1.     We note the disclosure you provided under "Unique Approach to Our Brand"
in response
       to prior comment 2, which includes the statement that your net revenues
"have been
       steadily increasing over the past several years along with [y]our earned
       impressions." If you retain disclosure relating to "earned media
impressions," please
       provide enhanced disclosure to clarify the nature of the nexus between
that metric and
 Ethan Brown
FirstName LastNameEthan Brown
Beyond Meat, Inc.
Comapany NameBeyond Meat, Inc.
October 26, 2018
October 26, 2018 Page 2
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FirstName LastName
         your results of operations or to make clear that there is none. Also
clarify the extent to
         which your management has used and intends to use this information in
managing your
         business. If management does not use the "earned media impressions"
metric in
         managing your business and it does not reflect or directly relate to
your past and
         anticipated results, it is unclear why that metric would be material
to investors and would
         enhance a reader's understanding of your business.
2.       Additionally, we note that the "earned media impressions" metric
appears to include
         significant limitations, such as possibly inflating the total amount
of exposure to content
         mentioning or featuring your brand or product by name. Please explain
to us why you
         believe that this metric would nonetheless be useful to investors.
Also, if true, please
         further clarify the potential for inflation due to double- or
multiple-counting of
         impressions repeated by more than one media outlet over time, discuss
further the
         limitations of such a metric, and disclose that the reader should not
place undue emphasis
         or reliance on such data given its limitations and lack of pertinence
as to how management
         manages the company's operations.
3.       If you retain the discussion, please expand it to address in necessary
detail the underlying
         assumptions you used to derive the "earned media impressions" metric.
Customers and Distributors, page 80

4.       We note that you previously discussed a number of significant
agreements, including
         those relating to licensing and sales. However, you appear to no
longer intend to file these
         agreements as exhibits, and you have removed the related disclosures.
You also disclose
         here and elsewhere that for 2017, your largest distributors in terms
of their respective
         percentages of your gross revenues included the following: UNFI, 38%,
KeHe, 10% and
         DOT, 10%, and that sales to Whole Foods, your largest customer, was
10%. Please
         explain why you no longer intend to file such agreements as exhibits
and why you have
         removed some of the related disclosures. In the alternative, please
summarize the material
         terms of these agreements and file these agreements as exhibits with
your next
         amendment. Refer to 601(b)(10)(ii)(B) of Regulation S-K.
Exhibit Index, page II-4

5.       We have received your application for confidential treatment and will
issue comments, if
         any, separately.
       You may contact Wei Lu, Staff Accountant, at 202-551-3725 or Jennifer
O'Brien, Staff
Accountant, at 202-551-3721 if you have questions regarding comments on the
statements and related matters. Please contact Irene Barberena-Meissner, Staff
Attorney, at 202-
551-6548 or, in her absence, Timothy S. Levenberg, Special Counsel, at
202-221-3707 with any
other questions.
 Ethan Brown
Beyond Meat, Inc.
October 26, 2018
Page 3

FirstName LastNameEthan Brown    Sincerely,
Comapany NameBeyond Meat, Inc.
                                 Division of Corporation Finance
October 26, 2018 Page 3          Office of Natural Resources
FirstName LastName