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    767
    Fifth Avenue

    New York, NY 10153-0119

    +1 212 310 8000 tel

    +1 212 310 8007 fax

January 19,
2022

VIA EDGAR TRANSMISSION

Suying Li

Rufus Decker

Securities and Exchange Commission

Division of Corporation Finance

100 F Street NE

Washington, D.C. 20549-3561

 Re: Dun & Bradstreet Holdings, Inc.

                                            Form 10-K for the Fiscal Year Ended December 31, 2020

                                            Filed February 25, 2021

                                            File No. 001-39361

Dear Ms. Li and Mr. Decker:

On behalf of our client, Dun & Bradstreet
Holdings, Inc., a Delaware corporation (the “Company”), set forth below are the Company’s responses to the comments
of the staff of the Securities and Exchange Commission (the “Staff”) communicated in its letter addressed to the Company,
dated December 22, 2021.

For ease of reference, the Staff’s comments
are reproduced below in bold and are followed by the Company’s response.

Form 10-K for the Fiscal Year Ended December 31, 2020

Management’s Discussion and Analysis of Financial Condition
and Results of Operations

Key Performance Measures, page 51

 1. Please present and discuss the comparable GAAP net income (loss)
                                            margin whenever Adjusted EBITDA margin is presented and discussed in your filings. Refer
                                            to Item 10(e)(1)(i) of Regulation S-K.

The Company acknowledges the Staff’s comment and
respectfully advises the Staff that it will modify its disclosure of Adjusted EBITDA margin in its future fillings to provide Net
income (loss) margin and give it equal or greater prominence, either immediately prior to the non-GAAP disclosure or in the
page preceding the non-GAAP disclosure. Please see below the proposed changes to the Company’s disclosure, which will be
included in its future filings, using its Form 10-K for the Fiscal Year December 31, 2020 as an example. Please also refer
to the supplemental documentation provided to the Staff for further illustration of the proposed changes.

    Suying Li

    Rufus Decker

    Securities and Exchange Commission

    January 19, 2022

    Page 2

The Company will add Net income (loss) margin in the table
presenting its GAAP historical results of operations on page 50, which is one page preceding the table for non-GAAP Financial
Measures you have referenced on page 51. The Company will add a heading “Net income (loss) margin” after “Net
income (loss) attributable to Dun & Bradstreet Holdings, Inc. (Successor)/The Dun & Bradstreet Corporation (Predecessor).”
The Company will also add a footnote to clarify how “Net income (loss) margin” is calculated. The footnote will read, “Net
income (loss) margin is defined as Net income (loss) attributable to Dun & Bradstreet Holdings, Inc. (Successor)/The Dun &
Bradstreet Corporation (Predecessor) divided by Revenue.”

The Company respectfully advises the Staff that it will
modify its disclosure of Adjusted EBITDA margin throughout its future reports. It will delete references of Adjusted EBITDA margin
on page 53. In addition, for the table “Adjusted EBITDA and adjusted EBITDA margin by segment” included on page 59, the
Company will include “Net income (loss) margin” under the header of “Consolidated total.” The Company will
also modify the paragraph discussing consolidated EBITDA margin on page 59 following the table discussed above by adding a sentence
discussing Net income (loss) margin before the sentence discussing Adjusted EBITDA margin.

Consolidated Financial Statements

Consolidated Statements of Operations and Comprehensive Income (Loss), page 85

 2. You present two confusingly similar line items: operating expenses
                                            and operating costs. It appears the operating costs line item represents your total operating
                                            expenses and the operating expenses line item represents only a portion of your operating
                                            expenses. Please retitle the operating expenses line item to better reflect what it actually
                                            represents. Also, breakout and separately present for each period the amounts of each material
                                            type of operating expense not included in cost of revenues or selling and administrative
                                            expenses. In addition, ensure that the applicable newly-titled operating expenses line item(s) reflect(s) the
                                            exclusion of depreciation and amortization. Refer to Rule 5-03.3 of Regulation S-X and
                                            SAB Topic 11:B.

The Company acknowledges the Staff’s comment and respectfully
advises the Staff that the Company will retitle the “Operating expenses” line item to “Cost of services (exclusive
of depreciation and amortization).” Consistent with page 46 of its Form 10-K for the year ended December 31, 2020, the Company
will provide the following revised definition for the retitled line item: Cost of services (exclusive of depreciation and amortization)
primarily include data acquisition and royalty fees, costs related to our databases, service fulfillment costs, call center and technology
support costs, hardware and software maintenance costs, telecommunication expenses, personnel-related costs associated with these functions
and occupancy costs associated with the facilities where these functions are performed. Please also refer to the supplemental documentation provided to the Staff for further illustration of the proposed changes.

    Suying Li

    Rufus Decker

    Securities and Exchange Commission

    January 19, 2022

    Page 3

The Company has considered whether any other material components
of costs of revenue should be further broken out as contemplated by Rule 5-03.3, 5-03.4, 5-03.5 or 5-03.6 of Regulation S-X. The
Company believes its revised presentation of consolidated statements of operations properly classifies its costs. The Company does not
believe there are other material types of operating expenses included in “Cost of services” or “Selling and administrative
expenses” that should be further broken out.

The Company has also considered the Staff’s interpretive
response provided in SAB Topic 11:B. The Company believes the retitled line item above “Cost of services (exclusive of depreciation
and amortization)” provides the necessary clarity. Gross depreciation and amortization is presented as a separate line item in
the income statement.

Should any questions arise in connection with
the filing or this response letter, please contact the undersigned at 212-310-8971.

    Sincerely yours,

    /s/ Alexander D. Lynch, Esq.

    Alexander D. Lynch, Esq.
 Weil, Gotshal & Manges LLP

    cc:
    Bryan Hipsher
 Chief Financial Officer

    Dun & Bradstreet Holdings, Inc.