SecProbe.io

April 7, 2020
Anthony M. Jabbour
Chief Executive Officer
Dun & Bradstreet Holdings, Inc.
103 John F. Kennedy Parkway
Short Hills, New Jersey 07078
Re:Dun & Bradstreet Holdings, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted on March 25, 2020
CIK No. 0001799208
Dear Mr. Jabbour :
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
Non-GAAP Financial Measures, page 17
1.We reviewed your response to comment one.  We believe that adjustments intended to
eliminate the impact of purchase accounting result in non-GAAP measures based on
individually tailored recognition and measurement methods.  Therefore, please revise
future filings to remove the deferred revenue purchase accounting adjustment from your
non-GAAP measures.  Refer to Question 100.04 of the non-GAAP C&DIs and Rule
100(b) of Regulation G.
2.Please expand your disclosures to clarify why your non-GAAP measures, that exclude
amortization of intangible assets, are useful to investors in light of the fact that the related
intangible assets appear to be directly related to the generation of revenue.

 FirstName LastNameAnthony M. Jabbour
 Comapany NameDun & Bradstreet Holdings, Inc.
 April 7, 2020 Page 2
 FirstName LastName
Anthony M. Jabbour
Dun & Bradstreet Holdings, Inc.
April 7, 2020
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 69
3.Please tell your consideration of discussing results of operations and financial condition
set forth in the audited financial statements supplemented by a discussion based upon
fiscal 2019 and 2018 pro forma financial information giving effect to the Take-Private
Transaction on January 1, 2018.  Please note that supplemental discussions based
on Article 11 of Regulation S-X pro forma financial information should not be presented
with greater prominence than the discussion of the historical financial statements required
by Item 303 of Regulation S-K.
Business, page 102
4.We note your response to comment 11 and we reissue the comment in part. Please also
quantify, to the extent possible, the percentage of your client contracts that are fixed price
subscription contracts versus per-item priced contracts or tell us where you have disclosed
this information.
5.We note your response to comment 12.  Please revise your disclosure to state how you
define strategic clients, and disclose the percentage of your clients that are strategic
clients.
6.We note in response to comment 14 you have revised your disclosure to state that in your
North American segment, 2% of your contracts are multi-year contracts.  Given the small
percentage that are multi-year contracts, please tell us why you believe the percentage
increase in such contracts is appropriate to highlight in the summary.  Please also tell us
why you believe that the current level of multi-year subscription contracts results in a
"high degree of revenue visibility" as you note elsewhere in the prospectus.
            You may contact Adam Phippen at 202-551-3336 or Ta Tanisha Meadows at 202-551-
3322 if you have questions regarding comments on the financial statements and related
matters.  Please contact Jennifer López at 202-5551-3792 or Erin Jaskot at 202-551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services