SecProbe.io

July 25, 2007

Room 4561

Mr. Jon Gacek
Executive Vice President, Finance and
  Chief Financial Officer
Quantum Corporation
11431 Willows Road
Redmund, WA  98052

Re: Quantum Corporation
 Form 10-K for Fiscal Ye ar Ended March 31, 2006
 Filed June 12, 2006
 File No. 001-13449

Dear Mr. Gacek:

We have reviewed your response to our letter dated April 13, 2007 in connection
with the above referenced filing and have th e following comments.  Please be as detailed
as necessary in your explanations.  In some of our comments, we may ask you to provide
us with supplemental information so we ma y better understand your disclosure.  After
reviewing this information, we may or  may not raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Year Ended March 31, 2006

Consolidated Financial Statements

Consolidated Statements of Operations, page 50
1. We note your response to prior comment 1 in our letter dated April 13, 2007 and
have the following additional comments re garding the nature of the settlement
with Storage Technology Corporation (STK):
• Describe in further detail the terms,  arrangements, obligations and rights
associated with the settlement consid eration elements received from STK.
Further, describe all ownership attributes  that reside in the patents or other
assets received such as transferability or exclusivity rights and
• Describe any assets receive d or liabilities incurred that are associated with
the STK settlement but were not pa rt of the stipulated agreement.

Mr. Jon Gacek
Quantum Corporation
July 25, 2007 Page 2
2. We have the following additional comments regarding valuation of elements received in the STK settlement:
• We believe that market place particip ant assumptions apply in valuing the
elements received for the settlement consideration.  Tell us how you considered use of mark et place participant assu mptions in view of
paragraph 9 of SFAS 142, paragraphs 5-7 of SFAS 141, paragraph B174 of SFAS 141 and paragraph 6 of EITF  02-17.  Identify assumptions used
in your valuations and explain why each is a market place participant
assumption.  Explain why you believe th e “Royalty Savings Method” is an
appropriate surrogate for a market pl ace participant determination of fair
value;
• Regarding the valuation of the patent s tell us what consideration you gave
to company specific assumptions versus marketplace participant
assumptions;
• Since you own the patents, explain how the royalty savings method, which generally looks to the rights and reward s inuring to a licensee, presents a
fair value that is materially simila r to a valuation me thod that addresses
the rights and rewards of ownership;
• Explain why you estimated the hypothetical royalty rate by use of a profit
split method and market comparable royalty rate as opposed to use of a
market rate alone;
• For patents you do not intend to use, tell  us if you would give them away
for no consideration and
• Tell us why you did not separately meas ure the fair value of the litigation
settlement cost element and explain your basis for the use of a residual approach in fair valuing the elements received rather than a relative fair
value model.
3. Litigation expense arising from cases other than shareholder lawsuits are ordinarily recorded within  cost of revenues or operating expenses.  Other than
shareholder litigation, we woul d not expect to see litiga tion settlements related to
operations of the company classified outside of operating expenses.  In this regard
tell us whether you consulted with the national office of Ernst & Young for the
recognition, valuation and classification i ssues related to the STK settlement and
if so, provide us with the basis for any conclusion from that office.

 * * * * * * *

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  Please submit all

Mr. Jon Gacek
Quantum Corporation
July 25, 2007 Page 3
correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T.  You may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cove r letter with any amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.

You may contact David E dgar, Staff Accountant, at (202) 551-3459 or the
undersigned at (202) 551-3730 if you have any questions regarding these comments.

Sincerely,

Craig Wilson
Senior Assistant Chief Accountant