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SEC Company Response from Direct Digital Holdings, Inc. (DRCT) (CIK 0001880613) (DRCT) — Feb 10, 2026

Direct Digital Holdings, Inc. (DRCT) (CIK 0001880613)
Date: Feb. 10, 2026 · CIK: 0001880613 · Accession: 0001880613-26-000018

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File numbers found in text: 333-293201

Date
February 10, 2026
Author
Diana P. Diaz
Form
CORRESP
Company
Direct Digital Holdings, Inc. (DRCT) (CIK 0001880613)

Letter

Document Direct Digital Holdings, Inc. 1177 West Loop South, Suite 1310 Houston, Texas 77027 VIA EDGAR February 10, 2026 Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549 Attention: Scott Anderegg Re: Direct Digital Holdings, Inc. Registration Statement on Form S-1 File No. 333-293201 Request for Acceleration of Effective Date Dear Mr. Anderegg: 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 February 11, 2026, 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

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CORRESP
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 Document Direct Digital Holdings, Inc. 1177 West Loop South, Suite 1310 Houston, Texas 77027   VIA EDGAR   February 10, 2026   Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, N.E. Washington, D.C. 20549 Attention: Scott Anderegg   Re:      Direct Digital Holdings, Inc. Registration Statement on Form S-1 File No. 333-293201     Request for Acceleration of Effective Date   Dear Mr. Anderegg: 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 February 11, 2026, 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