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CORRESP Filing

Getty Images Holdings, Inc.
Date: April 28, 2025 · CIK: 0001898496 · Accession: 0001213900-25-036142

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File numbers found in text: 333-286241

Date
April 28, 2025
Author
Craig Peters
Form
CORRESP
Company
Getty Images Holdings, Inc.

Letter

GETTY IMAGES HOLDINGS, INC.

605 5th Ave S. Suite 400

Seattle, WA 98104

April 28, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Eddie Kim

Division of Corporation Finance

RE: Getty Images Holdings, Inc. (the "Company")

Registration Statement on Form S-4

File No. 333-286241

Request for Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, the Company hereby respectfully requests that the effective date of the Company's Registration Statement on Form S-4 (File No. 333-286241) filed with the U.S. Securities and Exchange Commission (the "Commission") on March 31, 2025, as amended on April 28, 2025, be accelerated by the Commission to 4:00 p.m., Eastern Time, on April 30, 2025, or as soon as practicable thereafter.

We request that we be notified of such effectiveness by a telephone call to Todd Freed of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-3714 and that such effectiveness also be confirmed in writing.

Very truly yours,
Getty Images Holdings, Inc.

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CORRESP
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 GETTY IMAGES HOLDINGS, INC.

 605 5th Ave S. Suite 400

 Seattle, WA 98104

 April 28, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Eddie Kim

 Division of Corporation Finance

 RE: Getty Images Holdings, Inc. (the "Company")

 Registration Statement on Form S-4

 File No. 333-286241

 Request for Effectiveness

 Ladies and Gentlemen:

 Pursuant to Rule 461(a) under
the Securities Act of 1933, as amended, the Company hereby respectfully requests that the effective date of the Company's Registration
Statement on Form S-4 (File No. 333-286241) filed with the U.S. Securities and Exchange Commission (the "Commission") on March 31, 2025, as amended
on April 28, 2025, be accelerated by the Commission to 4:00 p.m., Eastern Time, on April
30, 2025, or as soon as practicable thereafter.

 We request that we be notified
of such effectiveness by a telephone call to Todd Freed of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-3714 and that such
effectiveness also be confirmed in writing.

 Very truly yours,

 Getty Images Holdings, Inc.

 By:
 /s/ Craig Peters

 Name:
 Craig Peters

 Title:
 Chief Executive Officer and Director

 cc:
 Todd E. Freed

 Skadden, Arps, Slate, Meagher & Flom LLP

 cc:
 Jon A. Hlafter

 Skadden, Arps, Slate, Meagher & Flom LLP