Correspondence 0001193125-24-240152 from Ingram Micro Holding Corp (INGM)
Ingram Micro Holding Corp
Date: Oct. 21, 2024 · CIK: 0001897762 · Accession: 0001193125-24-240152
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File numbers found in text: 333-282404
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CORRESP 1 filename1.htm CORRESP INGRAM MICRO HOLDING CORPORATION 3351 Michelson Drive, Suite 100 Irvine, California 92612 October 21, 2024 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549 Attn: Keira Nakada Rufus Decker Alyssa Wall Mara Ransom Re: Ingram Micro Holding Corporation Registration Statement on Form S-1 File No. 333-282404 Ladies and Gentlemen: Pursuant to Rule 461 of the Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Ingram Micro Holding Corporation (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-282404) (the “Registration Statement”) be accelerated so that it may become effective at 2:00 p.m., New York City time on October 23, 2024, or as soon as practicable thereafter, or at such other time as the Company or its legal counsel may request by telephone to the staff. Please orally confirm this request with our legal counsel, Cristopher Greer or Anne Barrett of Willkie Farr & Gallagher LLP. Our legal counsel has full authority to withdraw or modify this acceleration request, orally or in writing. Once the Registration Statement is effective, please contact Cristopher Greer of Willkie Farr & Gallagher LLP, counsel to the Company, at (212) 728-8214, or Anne Barrett at (212) 728-8466, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter. [Signature Page Follows] Sincerely, INGRAM MICRO HOLDING CORPORATION By: /s/ Paul Bay Name: Paul Bay Title: Chief Executive Officer