SecProbe.io

CORRESP
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 Document Direct Digital Holdings, Inc. 1177 West Loop South, Suite 1310 Houston, Texas 77027   VIA EDGAR   November 25, 2025   Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549   Re:      Direct Digital Holdings, Inc. Registration Statement on Form S-1 File No. 333-291106     Request for Acceleration of Effective Date   Ladies and Gentlemen:   Pursuant to Rule 461 under the Securities Act of 1933, as amended, Direct Digital Holdings, Inc. (the “ Company ”) hereby requests that the Securities and Exchange Commission (the “ Commission ”) accelerate the effective date of the above-referenced Registration Statement on Form S-1 (the “ Registration Statement ”) so that the Registration Statement will be declared effective as of 4:01 p.m. Eastern time on November 26, 2025, or as soon as practicable thereafter. The Company hereby authorizes Rakesh Gopalan or David S. Wolpa, both of whom are attorneys at the Company’s outside legal counsel, Troutman Pepper Locke LLP, to orally modify or withdraw this request for acceleration.   Once the Registration Statement has been declared effective, please orally confirm that event with Mr. Gopalan at (704) 916-2374 or Mr. Wolpa at (704) 916-2375.   Thank you for your assistance in this matter.                                          Very truly yours,                                              Direct Digital Holdings, Inc.                                              /S/ DIANA P. DIAZ                                  Name: Diana P. Diaz                              Title: Chief Financial Officer   cc (via email):    Rakesh Gopalan and David Wolpa, Troutman Pepper Locke LLP