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March 13, 2013

Via EDGAR

Securities and Exchange Commission
100
F Street, N.E.
Mail Stop 4561
Washington, D.C. 20549

      Attn:

    Patrick Gilmore

    Re:
    Quantum Corporation

    Form 10-K for the Fiscal Year Ended March 31, 2012

    Filed June 14, 2012

    Form 10-Q for the Quarterly Period Ended December 31,
      2012

    Filed February 8, 2013

    File No. 001-13449

Ladies and Gentlemen:

     Quantum
Corporation (the “Company,” “we,” “our,” or “Quantum”) submits this letter in
response to the comments from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) received by letter dated February 27,
2013 relating to the Company’s Form 10-K for Fiscal Year Ended March 31, 2012,
filed June 14, 2012 and Form 10-Q for the Quarterly Period Ended December 31,
2012, filed February 8, 2013.

       In this letter, we
have recited the comments from the Staff in italicized, bold type and have
followed each comment with the Company’s response.

Form 10-K for the Fiscal Year
Ended March 31, 2012

Item 8. Financial Statements and
Supplementary Data

Report of Independent Registered
Public Accounting Firm, page 44

    1.
    We note that you have included
      separate Statements of Comprehensive Income (Loss) on page 47 and that the
      first paragraph of the audit report does not reference these statements.
      Please amend your Form 10-K to include an opinion that references all of
      the audited financial statements. Refer to AU Section
      508.08.

Securities and Exchange
Commission
March 13, 2013
Page 2

Response:

Reference to the Statements of
Comprehensive Income (Loss) was inadvertently omitted from the opinion. On March
8, 2013 we filed an amended Form 10-K for inclusion of the corrected opinion.

Note 13 – Commitments and
Contingencies

Legal Proceedings, page
74

    2.
    We note that your statement
      regarding the Compression Technology Solutions LLC (CTS) patent
      infringement lawsuit indicates that “[d]ue to inherent uncertainty of
      litigation, [you] cannot identify probable or estimable damages.” We note
      similar disclosure included in your Form 10-Q for the quarterly period
      ended December 31, 2012 with respect to the CTS lawsuit and a patent
      infringement lawsuit with Overland Storage, Inc. If there is at least a
      reasonable possibility that a loss exceeding amounts already recognized
      may have been incurred, in your next periodic filing, either disclose an
      estimate (or, if true, state that the estimate is immaterial in lieu of
      providing quantified amounts) of the additional loss or range of loss, or
      state that such an estimate cannot be made. Refer to ASC
      450-20-50.

Response:

At this time, we do not believe there is
at least a reasonable possibility that a material loss exceeding amounts already
recognized may have been incurred with respect to either the CTS or Overland
lawsuits. If we reach the same conclusion based on our evaluation of the facts
and circumstances at the time of our next periodic filing, we will remove the
“[d]ue to inherent uncertainty of litigation, we cannot identify probable or
estimable damages” disclosure and include instead the following disclosure in
our Legal Proceedings footnote:

“We do not believe there is a reasonable possibility that we will pay
material damages related to these lawsuits.”

However, we confirm that if we determine
in the future that there is at least a reasonable possibility that a loss
exceeding amounts already recognized may have been incurred, we will update our
Legal Proceedings disclosure in the next applicable periodic filing to include
either an estimate of the additional loss or range of loss (or, if true, state
that the estimate is immaterial in lieu of providing quantified amounts), or
state that such an estimate cannot be made.

Securities and Exchange
Commission
March 13, 2013
Page 3

Form 10-Q for the Quarterly Period
Ended December 31, 2012

Item 1. Financial
Statements

Note 1 – Basis of Presentation,
page 5

    3.

    We note your disclosure on
      page 13 of your Form 10-Q for the quarterly period ended September 30,
      2012 that during the second quarter of fiscal 2013 you introduced a new
      product, Q-Cloud, that provides backup and disaster recovery on a
      subscription basis. Please provide us with the details and terms of these
      arrangements, including whether any implementation or set-up fees were
      earned, and your accounting policy for these cloud subscription
      services.

Response:

Our Q-Cloud arrangements are annual
subscriptions that provide the customer with hosted access to virtual backup and
disaster recovery in “the cloud,” as well as related technical support.
Customers do not have the contractual right to take possession of the underlying
software or other technology at any time during or after the subscription
period. Accordingly, based on the guidance of ASC 985-605-55-121 to 125, these
arrangements are outside the scope of ASC 985-605 and are accounted for as
service contracts. We recognize subscription fees as revenue ratably over the
annual contract period. These arrangements do not include any implementation or
set up fees. Q-Cloud revenue to date has been immaterial.

Note 4 – Intangible Assets and
Goodwill, page 6

    4.

    We note that you evaluate
      goodwill for impairment during the fourth quarter of the fiscal year or
      more frequently if indicators of impairment are present. We further note
      that your stock price has declined from $2.62 on March 30, 2012 to as low
      as $1.05 on October 31, 2012. You have also included disclosure on page 34
      regarding your decreasing stock price and the risk of NYSE delisting. In
      light of these factors, as well as your declining revenues, please tell us
      how you concluded that there were no indicators of goodwill
      impairment.

Securities and Exchange
Commission
March 13, 2013
Page 4

Response:

We operate as a single reporting unit and
perform our goodwill impairment assessment for the Company as a whole. As the
carrying amount of the reporting unit is negative, on an interim basis between
annual impairment tests we consider whether an event occurs or circumstances
exist that indicate that it is more likely than not that a goodwill impairment
exists in accordance with ASC 350-20-35-30. To make this determination, we
evaluated the examples of such events and circumstances included in ASC
350-20-35-3C(a) through (g). Also, in accordance with ASC 350-20-35-3F and G, we
evaluated on the basis of the weight of evidence the significance of identified
events and circumstances along with how they could affect the relationship
between the reporting unit's fair value and
carrying amount, including positive mitigating events and circumstances. An
overview of our considerations is as follows:

    a.
    Macroeconomic conditions such
      as a deterioration in general economic conditions, limitations on
      accessing capital, fluctuations in foreign exchange rates, or other
      developments in equity and credit markets

    b.
    Industry and market
      considerations such as a deterioration in the environment in which an
      entity operates, an increased competitive environment, a decline in
      market-dependent multiples or metrics (consider in both absolute terms
      and relative to peers), a change in the market for an entity's products or
      services, or a regulatory or political development

    c.
    Cost factors such as increases
      in raw materials, labor, or other costs that have a negative effect on
      earnings and cash flows

    d.
    Overall financial performance
      such as negative or declining cash flows or a decline in actual or planned
      revenue or earnings compared with actual and projected results of relevant
      prior periods

    Circumstances included in (a)
      through (c) all impacted our financial performance described in (d) to
      some extent, so we have combined our evaluation of these four factors. We
      had lower than expected revenue during the first half of our current
      fiscal year ended March 31, 2013 (“Fiscal 2013”) that was attributable in
      part to economic uncertainty, particularly in Europe, as well as a
      decrease in overall demand in the tape automation market. However, based
      on some key results in the second and third quarters of Fiscal 2013, we do
      not believe these factors are indicative of an ongoing adverse trend that
      would lead us to conclude it is more likely than not that a goodwill
      impairment exists. For example, during the quarter ended September 30,
      2012, we had year-over-year growth and record revenue in our disk and
      software category, which is our growth business. We also saw
      year-over-year growth in this revenue category during the quarter ended
      December 31, 2012 (“Q313”). Additionally, during Q313 we experienced
      sequential growth in tape automation revenue with the release of new
      technology and believe we are outperforming the market in this area. Total
      revenue for Q313 was within $600,000 of forecast and increased 8% from the
      second quarter of Fiscal 2013. Further, the long-term outlook in key
      market segments continues to be positive, with growth forecast for the
      disk-based deduplication and big data markets. Our disk and software
      products provide solutions in these growing markets.

Securities and Exchange
Commission
March 13, 2013
Page 5

    As part of our financial plan for
      Fiscal 2013, we increased our spending during the first half of the fiscal
      year in sales and marketing and certain other areas in an effort to drive
      revenue growth. Although gross margin percentages during Fiscal 2013 have
      remained relatively flat with the fourth quarter of Fiscal 2012, this
      increased spending combined with the revenue
      shortfall resulted in larger than expected operating losses and the use of
      cash in operations during the first half of Fiscal 2013. To mitigate the
      impact to operating profit and cash used in operations, during Q313 we
      implemented a restructuring plan to align spending with our revenue
      levels. These actions had a positive impact on Q313 results as we exceeded
      forecast gross margin by approximately 200 basis points, were at the low
      end of our operating expense forecast (excluding restructuring charges)
      and generated $6 million in cash from operations.

    The Q313 restructuring actions
      included headcount reductions of approximately 10% and saved an estimated
      $1 million during Q313 and are expected to save more in future quarters,
      as the full savings of the headcount and other cost reductions are
      realized. Historically, we have proven our ability to align spending with
      revenue levels by implementing measures to control expenditures quickly
      and decreasing operating expenses in successive quarters. For example, in
      connection with spending reductions initiated in response to the economic
      crisis of 2008, our operating expenses (excluding a goodwill impairment)
      decreased 20% between the quarters ended September 30, 2008 and June 30,
      2009 while maintaining gross margins around 38.5%.

    Due to demonstrated improvement
      in our Q313 results and our history of implementing cost controls, we
      concluded that our financial results for the first half of Fiscal 2013
      were not indicative of an ongoing negative trend that would lead us to
      conclude it is more likely than not that a goodwill impairment
      exists.

    e.
    Other relevant entity-specific
      events such as changes in management, key personnel, strategy, or
      customers; contemplation of bankruptcy; or litigation

    We have not experienced
      significant changes in management, strategy or customers, nor have we
      contemplated bankruptcy. During June 2012 Overland Storage, Inc.
      (“Overland”) filed a patent infringement lawsuit against us, but we do not
      believe we infringe on Overland’s patents and will defend ourselves
      vigorously. In August 2012 we filed a patent infringement lawsuit against
      Overland.

    f.
    Events affecting a reporting
      unit, such as a change in the composition or carrying amount of its net
      assets, a more-likely-than-not expectation of selling or disposing all, or
      a portion of a reporting unit, the testing for recoverability of a
      significant asset group within a reporting unit, or recognition of a
      goodwill impairment loss in the financial statements of a subsidiary that
      is a component of a reporting unit

    No such events have
      occurred.

Securities and Exchange
Commission
March 13, 2013
Page 6

    g.
    If applicable, a sustained
      decrease in share price (consider in both absolute terms and relative to
      peers)

    Although we have not had a
      closing stock price below $1.00 since August 17, 2009, as our stock price
      fell close to $1.00 at the end of October 2012, we felt it was prudent to
      include risk factor disclosure regarding the possibility of our stock
      price dropping below $1.00 and that a consequence of a closing stock price
      that averages less than $1.00 for a consecutive thirty trading-day period
      includes the risk of delisting on the NYSE. The stock price low of $1.05
      on October 31, 2012 occurred within one week of two events. First, our
      results for the quarter ended September 30, 2012 were released on October
      24, 2012. As described above, we have since taken steps to improve our
      financial results, and those actions have already had a positive impact on
      Q313 results. Second, we announced pricing for a convertible debt offering
      on October 26, 2012. The convertible debt proceeds were used to repay an
      existing bank line of credit, and we have subsequently modified certain
      covenants of that line of credit to be less restrictive. Our stock price
      increased 18% to $1.24 on December 31, 2012, and the closing price in
      November 2012 through December 2012 averaged $1.28, a 22% increase from
      the October 31, 2012 low. Closing prices during calendar 2013 through
      March 11, 2013 have ranged from a low of $1.21 to a high of $1.47. At the
      stock price low of $1.05, our market capitalization was approximately $250
      million, and at the current stock price as of March 11, 2013 it
      approximates $290 million.

Based on consideration of the factors
described above, we concluded that it was not more likely than not that a
goodwill impairment existed at an interim date.

Item 4. Controls and
Procedures

(a) Evaluation of disclosure
controls and procedures, page 24

    5.

    Please confirm whether your
      Chief Executive Officer and your Chief Financial Officer evaluated the
      effectiveness of your disclosure controls and procedures as defined in
      Rules 13a-15(e) and 15d-15(e) under the Exchange Act. Please also consider
      including the full definition of disclosure controls and procedures in
      future filings similar to the disclosure on page 76 of your Form 10-K for
      the fiscal year ended March 31, 2012 or alternatively, provide a reference
      to the definition of the rules (i.e. Rules 13a-15(e) and 15d-15(e) under
      the Exchange Act).

Securities and Exchange
Commission
March 13, 2013
Page 7

Response:

We confirm that our Chief Executive
Officer and our Chief Financial Officer evaluated the effectiveness of our
disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e)
under the Exchange Act for all quarterly periods in our current fiscal year,
including the quarter ended Dec