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July 10, 2014

VIA EDGAR

Securities and Exchange
Commission
Division of Corporation Finance
100 F Street, N.E.

Washington, DC 20549

    Attention:
    Maryse Mills-Apenteng, Special
  Counsel

    Jeff Kauten, Staff Attorney

    Re:

    Quantum
      Corporation

    Preliminary Proxy
      Statement on Schedule 14A

    Filed June 26,
      2014

    File No.
      001-13449

Ladies and Gentlemen:

On behalf of Quantum
Corporation (“Quantum,” or the “Company”), we are submitting this letter in
response to the comments from the staff (“Staff”) of the Securities and Exchange
Commission (the “Commission”) contained in the letter dated July 3, 2014 (the
“Comment Letter”) regarding the above referenced Preliminary Proxy Statement on
Schedule 14A. Concurrently with the filing of this letter, the Company has filed a revised Preliminary Proxy Statement on Schedule 14A (the “Revised Proxy Statement”). For your
convenience, we have repeated your comments below in italics, and the headings
and numbered responses in this response letter correspond to the headings and
numbered comments contained in the Comment Letter.

General

1. Please fill in the
blanks in your preliminary proxy statement.

     The
Company respectfully advises the Staff that the information required to fill in
the blanks is not known at this time, but the Company will fill in all blanks in
its definitive proxy statement

2. Please disclose that stockholders who grant a
proxy to you will be precluded from exercising their full voting authority for
the election of directors, given that you are proposing only five nominees for
seats on the board of directors.

     In response to the Staff’s comment, the
Company has amended the disclosure on pages 2 and 3 of the Revised Proxy Statement
to address the concerns noted in the Staff’s comment. The Company has included
additional disclosure highlighting the consequences to the Company’s
stockholders of using the Company’s proxy card to vote for the Company’s five
director nominees, namely that such stockholders will only be able to vote for
five of nine directors. The Company notes that such disclosure also appears in
Proposal One (Election of Directors).

Information Concerning
Solicitation and Voting

Solicitation, page
5

3. You indicate that proxies may be solicited by
certain of your officers, directors and regular employees personally or by
telephone, e-mail or otherwise. Please be advised that all written soliciting
materials, including any e-mails or scripts to be used in soliciting proxies,
must be filed under the cover of Schedule 14A on the date of first use. Refer to
Rule 14a-6(b) and (c). Please confirm your understanding.

     The
Company respectfully advises the Staff that it understands the requirements
under Rule 14a-6(b) and (c) and will file applicable materials accordingly.

4. We note your disclosure that regular employees of
the company may solicit proxies. Please describe the class or classes of regular
employees. See Item 4(b)(2) of Schedule 14A.

     The Company respectfully advises the Staff that it has determined that none of its regular employees will solicit proxies. Accordingly, the Company has deleted the disclosure on page 5 of the Revised Proxy Statement that regular employees of the Company may solicit proxies.

5. Please disclose the contracts with third parties
under which a change of control may be triggered by a change in a majority of
the seats on the board of directors.

     The
Company respectfully advises the Staff that it has amended the disclosure on
page 5 of the Revised Proxy Statement to state that a change in a majority of the
seats on the board of directors will constitute a change of control under
certain contracts with third parties, including the Company’s Credit Agreement
and its Directors’ and Officers’ Liability Insurance Policy.

Additional Information on
the Mechanics of Cumulative Voting, page 6

6. We note your disclosure that the Proxy Committee
may vote stockholders’ shares for fewer than nine nominees. Given that you are
only nominating five individuals for seats on the board of directors, it appears
to be certain that the Proxy Committee will vote for fewer than nine nominees.
Similar disclosure appears on page 20. Please advise.

     The Company respectfully advises the
Staff that it has amended the disclosure on page 6 of the Revised Proxy Statement to
clarify that the Proxy Committee may vote a stockholder’s shares for fewer than
all five of the Company’s nominees.

7. We note the following disclosure: “For example, if
you grant a proxy with respect to shares representing 900 cumulative votes, and mark “FOR ALL EXCEPT”
one of our director nominees, the Proxy Voting Committee may instruct the proxy holders to cast
the 900 votes for any or all of our five director nominees….” This appears to
state that the Proxy Committee may instruct the proxy holders to cast votes even
for the nominees for which the stockholder has withheld authority to vote.
Please advise.

     The Company respectfully advises the
Staff that it has amended the disclosures on page 6 of the Revised Proxy Statement to
clarify that the Proxy Voting Committee will only instruct the proxyholders to
cast votes only in accordance with the authority granted by the stockholder and
will not instruct the proxyholders to cast votes for any nominees for which the
stockholder has withheld authority.

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8. We note the following disclosure: “If you provide
vote allocation instructions for less than all of the votes that you are
entitled to cast, the proxy holders will retain discretionary authority to cast
your remaining votes pursuant to the instructions of the Proxy Committee, except
for any nominee for whom you have withheld authority by marking the ‘FOR ALL
EXCEPT’ box.” Please provide a mechanism for stockholders to avoid this result,
if they so wish.

     The
Company respectfully advises the Staff that the stockholders may avoid this
result by providing vote allocation instructions for all of the votes that such
stockholder is entitled to cast or marking the “FOR ALL” or “WITHHOLD ALL” box.
The Company has amended the disclosure on page 7 of the Revised Proxy Statement to
clarify that if a stockholder provides instructions as to all of the votes such
stockholder is entitled to cast, the proxyholders will vote in accordance with
such instructions.

Proposal One: Election of
Directors, page 19

9. Please disclose why you are only nominating five
directors for a nine-member board.

     The Company respectfully advises the
Staff that it has amended the disclosure on page 19 of the Revised Proxy Statement to
disclose its reasons for only nominating five directors for a nine-member board.

Proxy Card

10. Please state the order of priority of nominees to
which you will allocate votes, if known. If not known at this time, describe how
this determination will be made. Please also provide a means for stockholders to
affirmatively withhold authority to cumulate votes with respect to one or more
nominees.

     The Company respectfully advises the
Staff that it does not know at this time how it will specifically allocate votes
among the nominees. The Company has amended the proxy card to state that it will
allocate votes in a manner that will result in the election of the greatest
number of the Company’s nominees. The Company advises the Staff that the
stockholder may affirmatively withhold authority to cumulate votes with respect
to one or more nominees by marking the “FOR ALL EXCEPT” box and writing in the
number(s) of the applicable nominee(s) in the space provided. If the stockholder
wishes to specify the number of votes to be allocated to one or more nominees,
such stockholder may provide written instructions with respect to one or more
nominees in the space provided on the proxy card.

11. Please reconcile your disclosure on the proxy card
regarding broker non-votes with the disclosure appearing on page 2, which
asserts that there will not be any broker non-votes.

     The Company respectfully advises the
Staff that it has revised the proxy card to delete the reference to broker
non-votes.

12. Disclosure states that, if any named nominee
declines or is unable to serve as a director, the persons named as proxies will
have the authority to vote for substitute nominees. Please revise revise this
statement so that it is consistent with Rule 14a-4(c)(5).

     The Company respectfully advises the
Staff that it has revised the proxy card so that the referenced language is
consistent with Rule 14a-4(c)(5).

* * * * *

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The Company also acknowledges
that:

the Company is responsible for the adequacy and accuracy of the
  disclosure in the filing;

staff comments or changes to
  disclosure in response to staff comments do not foreclose the Commission from
  taking any action with respect to the filing; and

the Company may not assert staff
  comments as a defense in any proceeding initiated by the Commission or any
  person under the federal securities laws of the United States.

     Should the Staff have any additional comments or questions, please
contact me at (212) 497-7702
or my partner, Lisa Stimmell at (650)
849-3424. We respectfully request that the Staff confirm that it has no
additional requests or comments.

    Very
      truly yours,

    WILSON SONSINI GOODRICH & ROSATI

    Professional Corporation

    /s/
      Warren de Wied

    cc:
    Jon Gacek, Quantum
      Corporation
Shawn Hall, Quantum Corporation
Steven Bochner, Wilson
      Sonsini Goodrich & Rosati, PC
Lisa Stimmell, Wilson Sonsini
      Goodrich & Rosati, PC

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