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Correspondence 0001628280-25-054442 from Ingram Micro Holding Corp (INGM)

Ingram Micro Holding Corp
Date: Dec. 1, 2025 · CIK: 0001897762 · Accession: 0001628280-25-054442

AI Filing Summary & Sentiment

File numbers found in text: 333-291469

Date
December 1, 2025
Author
Ingram Micro Holding Corporation
Form
CORRESP
Company
Ingram Micro Holding Corp

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Re: Ingram Micro Holding Corporation Registration Statement on Form S-3 Filed November 12, 2025 File No. 333-291469

Dear Ms. Beukenkamp:

Reference is made to the Registration Statement on Form S-3 filed by Ingram Micro Holding Corporation (the “Company”) with the U.S. Securities and Exchange Commission on November 12, 2025 (File No. 333-291469) (the “Registration Statement”).

The Company hereby requests the Registration Statement be made effective at 4 p.m., Eastern Time, on December 3, 2025 (the “Effectiveness Time”), or as soon as possible thereafter, in accordance with Rule 461 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended.

If you have any questions related to this letter or if you require any additional information, please contact Cristopher Greer or Anne Barrett of Willkie Farr & Gallagher LLP at (212) 728-8214 or (212) 728-8466, respectively. Please notify either of them when this request for acceleration of effectiveness of the Registration Statement has been granted.

Very truly yours,
Ingram Micro Holding Corporation

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CORRESP
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Document

December 1, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attn: Kate Beukenkamp

Re:    Ingram Micro Holding Corporation

Registration Statement on Form S-3

Filed November 12, 2025

File No. 333-291469

Dear Ms. Beukenkamp:

Reference is made to the Registration Statement on Form S-3 filed by Ingram Micro Holding Corporation (the “Company”) with the U.S. Securities and Exchange Commission on November 12, 2025 (File No. 333-291469) (the “Registration Statement”).

The Company hereby requests the Registration Statement be made effective at 4 p.m., Eastern Time, on December 3, 2025 (the “Effectiveness Time”), or as soon as possible thereafter, in accordance with Rule 461 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended.

If you have any questions related to this letter or if you require any additional information, please contact Cristopher Greer or Anne Barrett of Willkie Farr & Gallagher LLP at (212) 728-8214 or (212) 728-8466, respectively. Please notify either of them when this request for acceleration of effectiveness of the Registration Statement has been granted.

Very truly yours,

Ingram Micro Holding Corporation

By: /s/ Augusto Aragone

 Name: Augusto Aragone

 Title: Executive Vice President, Secretary and General Counsel

Via E-mail:

cc:

 Cristopher Greer

 Anne Barrett

 Willkie Farr & Gallagher LLP