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CORRESP
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 RB Global, Inc.

 2 Westbrook Corporate Center
Westchester, IL

 Tel: 708-492-7282

 rbglobal.com

 June 18, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Scott Stringer and Joel Parker

 Re:
 RB Global, Inc.

 Form 10-K for fiscal year ended December 31,
2024

 File No. 001-13425

 Ladies and Gentlemen:

 We submit this letter in response to comments from the staff of the
United States Securities and Exchange Commission (the "Staff") to RB Global, Inc. (the "Company," "we,"
or "our") received by letter dated June 5, 2025 (the "Comment Letter"), relating to the above referenced Annual
Report on Form 10-K for the annual period ended December 31, 2024 filed on February 26, 2025 (the "2024 Annual Report"). For
your convenience, we have repeated the comments contained in the Comment Letter before the Company's response. Page references herein
correspond to the page of the 2024 Annual Report.

 Form 10-K for fiscal year ended December 31, 2024

 Notes to Consolidated Financial Statements

 5. Segment Information, page 73

 1. Please provide us with a detailed analysis of how you
determined you have one operating and reportable segment and revise your disclosure as applicable. In doing so explain whether you considered
geography or sectors as operating segments and clarify why your goodwill reporting units, Ritchie Bros, IAA and Services, do not qualify
as separate segments. Refer to ASC 280-10-50-1 through 50-9.

 Company response:

 We acknowledge the Staff's comment and respectfully advise the
Staff that the Company has assessed its operating and reportable segments pursuant to ASC 280 and concluded it has one operating and reportable
segment. Our detailed analysis of how we determined this is as follows:

 Operating Segments

 ASC 280-10-50-1 states that "An operating segment is a component
of a public entity that has all of the following characteristics:

 a. It engages in business activities from which it may recognize revenues and incur expenses (including revenues and expenses relating
to transactions with other components of the same public entity).

 b. Its operating results are regularly reviewed by the public entity's chief operating decision maker to make decisions about
resources to be allocated to the segment and assess its performance.

 c. Its discrete financial information is available."

 Each of these criteria has been assessed as follows:

 a. It engages in business activities from which it may recognize
revenues and incur expenses (including revenues and expenses relating to transactions with other components of the same public entity)

 The Company considered whether the criteria in ASC 280-10-50-1(a) would
apply to any of the Company's components, including Ritchie Bros., IAA, and those businesses included as part of the Services reporting
unit, and as a result would require further consideration over whether it may be an operating segment. The Company concluded that its
components engage in business activities from which they earn revenues and incur expenses.

 b. Its operating results are regularly reviewed by the public entity's
chief operating decision maker to make decisions about resources to be allocated to the segment and assess its performance

 In assessing this criterion, the Company first identified its Chief
Operating Decision Maker ("CODM") pursuant to the guidance in ASC 280-10-50-5, which states:

 "The term chief operating decision maker identifies
a function, not necessarily a manager with a specific title. That function is to allocate resources to and assess the performance of the
segments of a public entity. Often the chief operating decision maker of a public entity is its chief executive officer or chief operating
officer, but it may be a group consisting of, for example, the public entity's president, executive vice presidents, and others."

 The Company identified, and disclosed in its 2024 Annual Report, that
its CODM is its CEO, Jim Kessler, who is responsible for the following key operating decisions:

 · Determining the Company's overall strategy, including expanding into
new markets

 · Determining the organizational structure and providing direction to the executive
leadership team

 · Approving Company performance goals and compensation metrics

 · Evaluating Company performance

 · Determining how resources will be allocated across the organization

 · Approving and recommending the Company's annual budget and capital
plan to the Company's Board of Directors for approval

 Jim Kessler has been the Company's CEO since August 2, 2023.
The following roles report directly to the CODM (collectively referred to as the executive leadership team ("ELT")):

 · Chief
Financial Officer

 · Chief
Operating Officer

 · Chief
Revenue Officer

 · Chief
Technology Officer

 · Chief
Legal Officer

 · Chief
People Officer

 · Chief
Business Development Officer

 · EVP
 & Head of IAA Operations

 · EVP
 & Head of Global Product Management

 · Chief
Transformation Officer & Chief of Staff

 In 2024, the Company was organized by business function, such as finance
and accounting, legal, IT, human resources, sales, and operations. The functional areas operate on a companywide basis and support all
products and brands which comprise the Company's global marketplace that provides value-added insights, services, transaction solutions
for buyers and sellers of commercial assets and vehicles worldwide.

 The Company's organizational structure reflects the manner in
which the CODM evaluates performance and allocates resources, which is at the consolidated level. All of the CODM's direct reports,
with the exception of the EVP & Head of IAA Operations, have responsibility for consolidated functions. The EVP & Head of IAA
Operations is accountable only for IAA branch (i.e., salvage vehicle physical site location) operations, including branch operating costs,
assets, and headcount as well as compliance with service level agreements ("SLA") with automotive insurance company providers.
The EVP & Head of IAA Operations does not have accountability for IAA's revenues or other functional areas that are managed
on a consolidated basis such as finance and accounting, legal, IT, human resources, and operations.

 2

 In 2024, all members of the ELT (including the CODM) were compensated
through the Company's annual short-term and long-term incentive plans, where compensation is only tied to consolidated financial
measures and consolidated results of the Company. There were no CODM direct reports, who were compensated based on the financial results
of any sectors, geographies, or individual business activities.

 The following are regularly provided to the CODM:

 · Quarterly
 Business/Financial Review Report (the "Reporting Package"): Includes certain
 consolidated financial measures, including Gross Transaction Value ("GTV") 1 ,
 Revenue, Agency Proceeds 2 , adjusted cost of services, adjusted SG&A, adjusted
 gross margin, operating income, adjusted operating income, adjusted EBITDA, and adjusted
 EPS. The consolidated financial measures are compared to forecasted and prior period financial
 information, and reasons for the variances are highlighted in narrative form, which may include
 references to various businesses, sectors (such as Industrial and Salvage 3 ), or
 significant contracts, but only to the extent needed to explain the increase or decrease
 in the metric. Additionally, the Reporting Package includes certain consolidated metrics,
 including units sold, average selling price, agency proceeds rate, revenue per unit, and
 headcount information. The Reporting Package does not include the above information at any
 level below the consolidated level and does not include any profitability measures for IAA,
 Ritchie Bros., or Services. In addition, the Reporting Package includes capital expenditure
 on technology and properties, compared to forecasted and prior period financial information.

 The Board of Directors also receives the Reporting Package
on a quarterly basis.

 · Monthly
Forecast Review: Includes actual performance and forecasted financial information prepared on the same basis as the Reporting Package,
only at the consolidated level, for the CODM to review consolidated financial results compared to the most recently updated consolidated
forecast.

 The CODM also receives the following weekly reports which include both
financial and non-financial information; however, as set out below, these do not include any profitability measures:

 · IAA
Weekly Flash Primarily comprised of non-financial operating information intended to provide the CODM with a snapshot of IAA's operations
and performance in relation to SLAs with automotive insurance company providers. Non-financial operating information includes metrics
such as volume data, due date compliance, conversion rates, and branch KPI scores. Financial information included consists of GTV, average
tow cost per unit, and percentage change in average selling price.

 · Ritchie
Bros. Weekly GTV Dashboard: Primarily comprised of GTV and non-financial operating information (number of lots sold) intended to provide
the CODM with a snapshot of Ritchie Bros. channel volume. Financial information also includes percentage change in average selling price;
however, no cost information is included therein.

 The Annual Budget and Capital Plan is also prepared at a consolidated
level and is reviewed and approved by the CODM consistent with the manner in which the CODM reviews the ongoing results of the consolidated
business in the Reporting Package. The Annual Budget and Capital Plan only includes consolidated profitability measures and does not include
any component level profitability measures.

 1 GTV
represents total proceeds from all items sold on the Company's auctions and online marketplaces, third-party online marketplaces,
private brokerage services and other disposition channels. GTV is not a measure of financial performance, liquidity, or revenue, and
is not presented in the Company's consolidated financial statements in the 2024 Annual Report.

 2 Agency
Proceeds is calculated by subtracting the cost of inventory sold and certain ancillary and logistical service expenses from total revenues.

 3 Industrial
and Salvage generally conform with Ritchie Bros. and IAA, respectively.

 3

 In response to the Staff's question on whether geography or sectors
were considered as operating segments, the CODM does not regularly review operating results by sector or geography. Within Item 7. Management's
Discussion and Analysis of Financial Condition and Results of Operations of the Company's 2024 Annual Report and Quarterly Earnings
Reports on Form 8-K, the Company discloses GTV and total lots sold by sector, as well as GTV by geography; however, operating results
are not disclosed or reviewed by the CODM regularly by sector or geography.

 Based on the foregoing, the Company concluded that its CODM reviews
operating results on a consolidated company basis to make key decisions about resources to be allocated to the business and assess its
performance.

 c. Its discrete financial information is available

 Discrete financial information is available for each of the Company's
components; however, as discussed above, the CODM does not regularly review discrete financial information for any of the Company's
components, sectors, or by geography.

 Considering the facts and circumstances noted above, the CODM operates
the business and makes resource allocation and performance assessment decisions only at the consolidated level. Accordingly, the CODM
does not evaluate the performance of the Company or allocate resources at any level below the consolidated level or based on the Company's
assets or liabilities.

 Reportable Segments

 ASC 280-10-50-10 states that "A public entity shall report
separately information about each operating segment that meets both of the following criteria:

 a. Has been identified in accordance with paragraphs 280-10-50-1
and 280-10-50-3 through 50-9 or results from aggregating two or more of those segments in accordance with the following paragraph

 b. Exceeds the quantitative thresholds in paragraph 280-10-50-12."

 As the Company has concluded it has a single operating segment, it
therefore has a single reportable segment.

 Reporting Units

 A reporting unit, as defined in ASC 350-20-20, is the level of reporting
at which goodwill is tested for impairment. A reporting unit is an operating segment or one level below an operating segment (also known
as a component).

 As part of identifying its reporting units, the Company identified
its segment management pursuant to the guidance in ASC 280-10-50-7, which states:

 "Generally, an operating segment has a segment manager
who is directly accountable to and maintains regular contact with the chief operating decision maker to discuss operating activities,
financial results, forecasts, or plans for the segment. The term segment manager identifies a function, not necessarily a manager with
a specific title."

 Considering this guidance, the Company determined that its segment
management included a subset of the ELT, which does not include the CODM.

 The Company considered the definition of a reporting unit under ASC
350-20-35-34:

 "A component of an operating segment is a reporting
unit if the component constitutes a business or a nonprofit activity for which discrete financial information is available and segment
management, as that term is defined in paragraph 280-10-50-7, regularly reviews the operating results of that component. Subtopic 805-10
includes guidance on determining whether an asset group constitutes a business."

 4

 Other than as discussed above, review of operating results for levels
below the consolidated level is not performed by, or including, the CODM. A sub-group of the ELT, excluding the CODM, regularly reviews
the operating results of each of Ritchie Bros., IAA and Services components in their role as segment management. Accordingly, the Company
concluded that it had three reporting units at December 31, 2024: Ritchie Bros., IAA, and Services. The Company's reporting units
therefore do not qualify as operating segments due to the varying definitions of operating segments and reporting units in ASC 280 and
ASC 350, respectively. The reporting units do not meet the criteria in ASC 280-10-50-1(b), as component operating results are not regularly
reviewed by the CODM to allocate resources and assess performance.

 8. Income Taxes, page 79

 2. Please disclose the domestic and foreign components
of your income before income tax expense. Refer to Rule 4-08(h)(1) of Regulation S-X.

 Company response:

 We acknowledge the Staff's comment and respectfully advise the
Staff that we will disclose the domestic 4 and foreign components of earnings before income tax in future filings.

 We note that in Footnote 8, "Income Taxes" the reader could
derive the information as we disclose the following , "Permanently reinvested undistributed pre-tax earnings of the Company's
foreign subsidiaries were approximately $297.6 million for the year ended December 31, 2024 (2023: $113.1 million; 2022:
$93.1 million)." In addition, we disclose consolidated earnings before tax of $550.1 million. The $297.6 million represents
our foreign earnings before tax, and the difference between that number and the consolidated earnings before tax of $550.1 million is
our total domestic earnings before tax of $252.5 million.

 4 As
stated in Note 1 to Rule 4-08(h)(1) of Regulation S-X, "foreign income (loss) is defined as income (loss) generated from a registrant's
foreign operations, i.e., operations that are located outside of the registrant's home country." The Company
is incorporated in Canada and theref