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    Peter Seligson

    To
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    peter.seligson@kirkland.com

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    United States

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    www.kirkland.com

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    VIA EDGAR

    March 15, 2022

    Securities and Exchange Commission
 Division of Corporation
Finance
 Office of Trade & Services
 100 F Street, N.E.
 Washington, D.C. 20549
 Attention: Stacey K. Peikin

                           Lilyanna
Peyser

                           Tony Watson

                           Adam Phippen

 Re: Vector Holding, LLC

Registration Statement on Form S-4

Filed January 18, 2022

File No. 333-262203

Ladies and Gentlemen:

On behalf of our client, Vector Holding, LLC (the
 “Registrant”), we set forth below the Registrant’s response to the letter, dated February 17, 2022, containing
the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) with respect to the above referenced Registration Statement on Form S-4 filed by the Registrant
on January 18, 2022 (the “Registration Statement”).

In order to facilitate your review, we have restated
the Staff’s comments in this letter, and we have set forth the Registrant’s responses immediately below the Staff’s
comments.

In addition, the Registrant has revised the Registration
Statement in response to the Staff’s comments and is confidentially submitting an amendment to the Registration Statement (the “Amendment”)
concurrently with this letter, which reflects the revisions and clarifies certain other information. The page numbers in the text of the
Registrant’s responses correspond to the page numbers in the Amendment. Unless otherwise indicated, capitalized terms used herein
have the meanings assigned to them in the Amendment.

    Austin
      Bay Area   Beijing   Boston   Brussels   Chicago   Dallas   Hong Kong   Houston   London   Los Angeles   Munich   Paris   Salt Lake City
      Shanghai   Washington, D.C.

    Securities and Exchange Commission

    March
    15, 2022

    Page
    2

Form S-4 filed January 18, 2022

Market and Industry Data, page 10

 1. Staff’s comment: We note your statements that “there can be no assurance as
to the accuracy or completeness of such information” and “neither Getty Images nor CCNB has independently verified the information
and cannot guarantee the accuracy and completeness of such information.” Under the federal securities laws, you are responsible
for all information contained within your registration statement and should not include language that suggests otherwise. Please delete
these statements.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on page 10 of the Amendment.

 2. Staffs comment: Please tell us whether you commissioned any of the market and industry
data used in this filing. If applicable, file the consents of such parties as an exhibit to your registration statement, or tell us why
you do not believe you are required to do so. See Rule 436 and Section 7 of the Securities Act. In this regard, we note your disclosure
on page 19 regarding data from InsightSlice, PubMatic, The World Federation of Advertisers, and Kauman Index.

Response:
The Registrant respectfully advises the Staff that none of the third-party data was commissioned by us for use in connection
with the Registration Statement. Accordingly, we are not required to file any consents pursuant to Rule 436 of the Securities Act.

Summary of the Proxy Statement/Prospectus, page 13

 3. Staffs comment: We note your presentation of FY 21E Gross Margin here and on page 223.
We also note your disclosure on page F-63 that cost of revenue excludes depreciation and amortization associated with creating or buying
content. To the extent the gross margin estimates are not computed with a fully-burdened cost of revenues, these margins are non-GAAP
measures. Please tell us whether these estimates are non-GAAP measures and your basis for such conclusion. To the extent they are non-GAAP
measures, please disclose in equal or greater prominence a fully burdened gross margin prepared in accordance with GAAP. Additionally,
when reconciling to these non-GAAP measures, please reconcile from a fully-burdened gross profit. Refer to Item 10(e)(1)(i)(A) and (B)
of Regulation S-K.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure to remove the reference to Gross Margin
on pages 13 and 236 of the Amendment.

    Securities and Exchange Commission

    March
    15, 2022

    Page
    3

CCNB Board’s Reasons for the Approval of the Business Combination,
page 17

 4. Staffs comment: We note the discussion of management’s due diligence activities on
page 18. Please revise the fifth bullet to provide more detail on your evaluation of NFT monetization opportunities.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 18 and 166 of the Amendment.

Interests of CCNB’s Directors and Officers and Others in the
Business Combination, page 29

 5. Staff comment: Revise the penultimate bullet on page 31 to disclose the amount of reimbursable
out of pocket expenses that have been incurred by the sponsor.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 32, 54, 95 and
152 of the Amendment.

 6. Staff comment: Please revise to include a bullet that discloses, upon completion of the
business combination, the ownership of New CCNB by the related persons. Please quantify the related persons equity position and its relative
value in terms of the overall transaction. To the extent quantifiable, please include the related persons rate of return on their initial
investment in CCNB. Please include similar disclosure elsewhere as appropriate.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 31, 53, 93 and
150 of the Amendment.

The Registrant respectfully advises the Staff that it
is not practicable to quantify the related persons’ rate of return because, amongst other things, the timing (including as a
result of the twelve-month lockup applicable to the founder shares) and price at which the related persons sell the
Registrant’s securities is uncertain, both of which would have a material impact on the applicable rate of return. In
addition, the Sponsor and the Independent Directors may be required to forfeit shares in connection with the Business Combination,
and the total number of shares that may be required to forfeit will not be known until the earlier of ten years post-closing, and
the date on which the applicable vesting event is satisfied. Any such forfeitures of shares would also have a material impact on the
related persons’ rate of return.

    Securities and Exchange Commission

    March
    15, 2022

    Page
    4

 7. Staff comment: Please tell us, with a view toward disclosure, whether your sponsor, officers
and directors have any fiduciary or contractual obligations to other entities and, if so, how the board considered those conflicts in
negotiating and recommending the business combination.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 33, 56 and 153
of the Amendment.

Questions and Answers About the Proposals for Shareholders

What consideration will be received in connection with the Business Combination?, page 46

 8. Staff comment: Please revise the answer to clarify the relative value of the various types
of consideration discussed in this answer. In addition, please discuss the Earn-out Shares in greater detail, including the number of
shares to be issued to the various recipients and the applicable vesting triggers.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 50 and 51 of the Amendment.

The Registrant respectfully advises the Staff that it is
not practicable to quantify the relative value of the Earn-Out Shares, given that the total number of Earn-Out Shares that will be issued
to the Getty Images Stockholders will not be known until the earlier of ten years post-closing, and the date on which the applicable triggering
event is satisfied.

What equity stake will the current shareholders of CCNB, Multiply
Group and the current shareholders of Getty Images hold in Getty Images…, page 47

 9. Staff comment: Please revise to also include the Sponsor’s percentage ownership including
the “2,570,000 shares of New CCNB Series B-1 Common Stock and 2,570,000 shares of New CCNB Series B-2 Common Stock subject to certain
vesting restrictions pursuant to the Sponsor Side Letter, any shares to be issued to the Sponsor in connection with the PIPE Investment
and NBOKS in connection with the Backstop Agreement,” and the Getty Family Stockholders’ percentage ownership including “shares
purchased in connection with the PIPE Investment. In addition, we note that you provide the percentage ownership for CCNB’s public
shareholders and the Sponsor in the event that all of the New CCNB Warrants are exercised; please also provide the percentage ownerships of the other stockholder
groups in such case. Finally, clarify whether and how the earn-out shares are considered in the percentage ownerships identified in this
Q&A.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 51 and 52 of the Amendment.

    Securities and Exchange Commission

    March
    15, 2022

    Page
    5

The Registrant respectfully advises the Staff that the total
number of Earn-Out Shares that will be issued to the Getty Images Stockholders will not be known until the earlier of ten years post-closing,
and the date on which the applicable triggering event is satisfied.

Sponsor Group Ownership of New CCNB Following the Business Combination,
page 49

 10. Staff comment: Please revise footnotes 1 and 3 to the table to include the total value
of the excluded shares identified in each footnote. Also clarify whether and how the earn-out shares are considered in this table.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 32, 54, 94 and 151 of the Amendment.

The Registrant respectfully advises the Staff that the Sponsor
will not receive any Earn-Out Shares following the consummation of the Business Combination, and thus, the Earn-Out Shares are not considered
in this table.

What happens if a substantial number. . . ., page 53

 11. Staff comment: Please revise to disclose the potential impact of redemptions on the per
share value of the shares held by non-redeeming shareholders. In addition, we note that (i) the second row of the first table excludes
New CCNB Series B-1 Common Stock and New CCNB Series B-2 Common Stock, the shares to be issued to the Sponsor in connection with the Pipe
Investment and the shares to be issued to NBOKS in connection with the Backstop Agreement, (ii) the last row of the first table excludes
New CCNB Warrants, and (iii) the first row of the second table excludes New CCNB Warrants issuable upon conversion of the Working Capital
Loans; please provide additional disclosure regarding the redemption scenarios that includes such excluded shares, or tell us why such
disclosure is not material.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 58, 59, 109 and 110 of the
Amendment accordingly.

    Securities and Exchange Commission

    March
    15, 2022

    Page
    6

Can the Sponsor and the Independent Directors redeem their Founder
Shares. . . ., page 61

 12. Staff comment: We note that the “Sponsor, the Founder Holders and certain of CCNB’s
directors and/or officers…have agreed, for no additional consideration, to waive their redemption rights with respect to
their Founder Shares and any public shares they may hold in connection with the business combination.” (emphasis added). Please
describe any consideration provided in exchange for these agreements, if any.

Response:
The Registrant respectfully advises the Staff that the Sponsor, the Founder Holders and certain of CCNB’s directors and/or officers
were provided no consideration in exchange for executing the letter agreements with CCNB.

Risk Factors

Risks Related to COVID-19 Pandemic and Global Economic Conditions, page 64

 13. Staff comment: Please revise, to the extent possible, to quantify the negative impacts
COVID-19 has had on the Getty Images business and operations. Please include enough detail so that shareholders can appreciate the discussed
risk. Similarly, revise page 241 to quantify the impacts of COVID on your business for the periods presented.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 70 and 71 of the Amendment.

Expansion of our operations into new products, services and technologies…,
page 68

 14. Staff comment: Please expand your discussion to disclose the extent your operations have
expanded to the additional products and services mentioned in this risk factor, including non-fungible tokens, artificial intelligence,
and machine learning so that shareholders can appreciate the discussed risk.

Response:
The Registrant respectfully acknowledges the Staff’s comment has revised the disclosure on page 74 of the Amendment.

    Securities and Exchange Commission

    March
    15, 2022

    Page
    7

Unless we increase customer and supplier awareness…, page
71

 15. Staff comment: We note the heading of this risk states that “our revenue may not
continue to grow;” however, we note that your revenue decreased between 2020 and 2021. Please revise this heading to more clearly
disclose the risk.

Response:
The Registrant respectfully advises the Staff that the accompanying consolidated statements of operations of Griffey Global Holdings,
Inc. show an increase in revenue between 2020 and 2021 from $815.4 million to $918.7 million.

Risks Related to the Business Combination and CCNB, page 147

Our Existing Warrant Agreement…., page 91

 16. Staff comment: We note your discussion of the exclusive forum provision in the Existing
Warrant Agreement and its applicability to claims under the Exchange Act and Securities Act, however the Existing Warrant Agreement does
not appear to contain such a provision. Please revise your risk factor disclosure, the disclosure in Description of New CCNB Securities
and/or warrant agreement as necessary.

Response:
The Registrant respectfully acknowledges the Staff’s comment and has removed the disclosure on page 98 of the Amendment.

The New CCNB Post-Closing Certificate of Incorporation will designate
the Court of Chancery of the State of Delaware…, page 108

 17. Staff comment: We note that the forum selection provision in the New CCNB Post-Closing
Certificate of Incorporation identifies the Court of Chancery of the State of Delaware as the exclusive forum for certain litigation,
including any “derivative action.” Please disclose whether this provision applies to actions arising under the Exchange Act.
In that regard, we note that Section 27 of the Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce any
duty or liability created by the Exchange Act or the rules and regulations thereunder. If this provision does not apply to actions arising
under the Exchange Act, please revise to clarify that fact and ensure that the exclusive forum provision in the governing documents states
this clearly. In addition, please revise here to disclose whether this exclusive forum provision applies to actions arising under the
Securities Act. In that regard, we note that Section 22 of the Securities Act creates co