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September 30, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Canadian Imperial Bank of Commerce

Registration Statement on Form F-3

File No. 333-282307

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of
1933 (the “Act”), Canadian Imperial Bank of Commerce (the “Registrant”) hereby requests that the
above-referenced Registration Statement on Form F-3, as amended (the “Registration Statement”), be declared effective
at 5:00 p.m., Eastern Time on October 2, 2024, or as soon as practicable thereafter.

Once the Registration Statement has been declared
effective, it would be appreciated if you would so inform Edward S. Best via telephone at (312) 728-9158 or via e-mail at EBest@willkie.com
or Susan Rabinowitz via telephone at (312) 728-9087 or via e-mail at SRabinowitz@willkie.com.

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Thank you for your assistance in this matter.

    Very truly yours,

    Canadian Imperial Bank of Commerce

    By:
    /s/ Achilles M. Perry

    Name: Achilles M. Perry

    Title:
    Vice President and General Counsel – Capital Markets (U.S., Europe, Asia)

    Canadian Imperial Bank of Commerce