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 Skadden,
Arps, Slate, Meagher & Flom llp

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 October 9, 2025
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 SUBMISSION VIA EDGAR

 Division of Corporation Finance
Office of Trade & Services
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 Attn:
 Robert Shapiro

 Lyn Shenk

 Re: Getty Images Holdings, Inc.

 Form 10-K for Fiscal Year Ended December 31,
2024

 Form 10-Q for Fiscal Quarter Ended June 30,
2025

 File No. 001-41453

 Ladies and Gentlemen:

 On behalf of Getty Images Holdings, Inc. (the " Company ")
and in response to the comments of the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the
" Commission ") on the Company's Form 10-K for Fiscal Year Ended December 31, 2024 (the " Form 10-K ")
and the Company's Form 10-Q for Fiscal Quarter Ended June 30, 2025 (the " Form 10-Q ") set
forth in the Staff's comment letter dated September 26, 2025 (the " Comment Letter "), set forth below
are the Company's responses to the Comment Letter.

 The headings and paragraph numbers in this letter
correspond to those contained in the Comment Letter and, to facilitate the Staff's review, we have reproduced the text of the Staff's
comments in italics below. Capitalized terms used but not defined herein have the meanings given to them in the Form 10-K and Form 10-Q,
as applicable. All references to page numbers and captions (unless otherwise stated) in our responses correspond to the page numbers and
captions in the Form 10-K and Form 10-Q, as applicable.

 Division of Corporation Finance

 Office of Trade & Services

 Securities and Exchange Commission

 October 9, 2025

 Page 2

 Form 10-K for the Fiscal Year Ended December 31,
2024

 Note 13. Commitments and Contingencies
Contingencies, page F-26

 1. With regard to the Initial and Follow-On Warrant Litigation, you disclose on page F-29 you have made certain litigation reserves
in the Consolidated Statements of Operations. You also disclose you do not currently believe that a material loss arising from the final
disposition of existing matters is probable. Please reconcile these disclosures for us.

 Response : The Company acknowledges
the Staff's comment and in future filings will clarify for which matters the Company has established litigation reserves. The following
represents an illustrative example of the disclosure the Company intends to include in its future filings:

 The Company has made litigation reserves
in respect of the Initial Warrant Litigation and the Berner/Lapp Actions. Although the Company cannot be certain of the outcome of any
litigation or the disposition of any claims, or the amount of damages and exposure, if any, that the Company could incur, the Company
does not currently believe that a material loss arising from the final disposition of existing matters, other than those in respect of
which the Company has made litigation reserves as described above, is probable. Due to the inherent uncertainties of litigation and regulatory
proceedings, we cannot determine with certainty the ultimate outcome of any such litigation or proceedings. If the final resolution of
any such litigation or proceedings is unfavorable, our financial condition, results of operations and cash flows could be materially affected.
Further, in the ordinary course of business, the Company is also subject to periodic threats of lawsuits, investigations and claims. Regardless
of the outcome, litigation can have an adverse impact on the Company because of defense and settlement costs, diversion of management
resources and other factors.

 Form 10-Q for Fiscal Quarter Ended June 30, 2025

 Condensed Consolidated Statements of Cash Flows, page 5

 2. Please disclose the amounts for interest and income taxes paid for the six months ended June 30, 2025 and 2024. Refer to ASC
230-10-50-2 and 2A.

 Response : The Company respectfully
acknowledges the Staff's comment and believes that the requirement pursuant to ASC 230-10-50-2 and ASC 230-10-50-2A to disclose
the amount of cash paid for interest and income taxes paid is only applicable to annual financial statements. However, in future quarterly
reports filed with the Commission, the Company intends to augment its disclosure to include the cash paid for interest and income taxes,
consistent with the disclosure within the Form 10-K. Such disclosure, had it been included in the Form 10-Q, would have been
the following:

 Six Months Ended June 30,

 2025
 2024

 Interest paid
 $ 55,646
 $ 65,285

 Income taxes paid, including foreign taxes withheld
 $ 23,400
 $ 17,800

 Division of Corporation Finance

 Office of Trade & Services

 Securities and Exchange Commission

 October 9, 2025

 Page 3

 Management's Discussion and Analysis of Financial Condition
and Results of Operations

 Results of Operations

 Foreign exchange loss (gain) - net, page 30

 3. Please enhance your disclosure to explain how the use of Euro-denominated term debt and your exposure to foreign exchange fluctuations
due to the generation of a significant portion of your revenues from foreign countries has impacted your results of operations and financial
condition for the three and six months ended June 30, 2025. Refer to Items 303(a) and (c) of Regulation S-K.

 Response : The Company acknowledges
the Staff's comment and, in future filings, will enhance its disclosures surrounding the impact of foreign exchange fluctuations,
in particular with regard to the Company's exposure resulting from foreign country revenues and its use of Euro-denominated debt.
The following represents an illustrative example of the disclosure the Company intends to include in future filings, using the three and
six-month periods ended June 30, 2025 and 2024 provided in the Form 10-Q:

 Results of Operations

 Comparison of the Three Months Ended June 30,
2025 and 2024

 For the three months ended June 30,
2025, total revenue on a reported basis was $234.9 million as compared to $229.1 million for the three months ended June 30, 2024.
On a reported basis, revenue increased by 2.5% (1.8% CN) for the three months ended June 30, 2025. Foreign exchange movements positively
impacted reported revenue growth for the three months ended June 30, 2025 by 70 basis points, largely driven by the weakening dollar
relative to the EUR and GBP.

 Foreign exchange (loss) gain –
net

 We recognized foreign exchange loss, net
of $54.8 million for the three months ended June 30, 2025, compared to net gains of $2.4 million for the three months ended June 30,
2024. These changes are primarily driven by fluctuations in the EUR related to our Old EUR Term Loans and New EUR Term Loans, which resulted
in a foreign currency loss of $38.6 million for the three months ended June 30, 2025 and a foreign currency gain of $3.4 million
for the three months ended June 30, 2024.

 Division of Corporation Finance

 Office of Trade & Services

 Securities and Exchange Commission

 October 9, 2025

 Page 4

 We expect continued volatility in foreign
exchange gains and losses each quarter based on fluctuations in exchange rates impacting our foreign currency exposures.

 Comparison of the Six Months Ended June 30,
2025 and 2024

 For the six months ended June 30, 2025,
total revenue on a reported basis was $459.0 million as compared to $451.4 million for the six months ended June 30, 2024. On a reported
basis, revenue increased by 1.7% (2.1% CN) for the six months ended June 30, 2025. Foreign exchange movements negatively impacted
reported revenue growth for the six months ended June 30, 2025 by 40 basis points, largely driven by the stronger dollar relative
to the EUR in the first quarter of 2025.

 Foreign exchange (loss) gain –
net

 We recognized foreign exchange losses, net
of $79.8 million for the six months ended June 30, 2025, compared to net gains of $18.9 million for the six months ended June 30,
2024. These changes are primarily driven by fluctuations in the EUR related to our Old EUR Term Loans and New EUR Term Loans, which resulted
in a foreign currency loss of $56.8 million for the six months ended June 30, 2025 and a foreign currency gain of $15.1 million for
the six months ended June 30, 2024.

 We expect continued volatility in foreign
exchange gains and losses each quarter based on fluctuations in exchange rates impacting our foreign currency exposures.

 Liquidity and Capital Resources,

 Operating Activities, page 35

 4. Please provide a more informative analysis and discussion of changes in cash flows, including changes in working capital components,
for each period presented. In doing so, explain the underlying reasons and implications of material changes between periods to provide
investors with an understanding of trends and variability in cash flows from operating activities. Ensure your discussion and analysis
is not merely a recitation of changes evident from the financial statements. Refer to Item 303(a) of Regulation S-K and sections IV.B
and IV.B.1 of SEC Release No. 33-8350.

 Response : The Company respectfully
acknowledges the Staff's comment and, in future filings, will provide additional analysis and discussion of changes in cash flows,
including changes in working capital. The following represents an illustrative example of the presentation and discussion that the Company
intends to include in future filings, using the six-month periods ended June 30, 2025 and 2024 provided in the Form 10-Q:

 For the six months ended June 30, 2025,
cash provided by operating activities was $21.9 million, as compared to cash provided by operating activities of $68.0 million for the
six months ended June 30, 2024. The decrease in cash provided by operating activities was primarily driven by merger related costs,
of which $26.3 million were paid in the six-month period ending June 30, 2025. These costs were comprised mainly of professional
services fees, including legal, advisory, accounting and tax fees. In addition, our cash provided by operating activities was impacted
by changes in working capital, including reduced cash flows from the change in timing of collections of accounts receivable and the payments
of accrued expenses, increased cash flows from the timing of payments for accounts payable and interest, changes in deferred revenue and
an increase in cash paid for taxes of $5.6 million for the six months ended June 30, 2025 as compared to the six months ended June 30,
2024.

 ***

 Division of Corporation Finance

 Office of Trade & Services

 Securities and Exchange Commission

 October 9, 2025

 Page 5

 We hope that the foregoing has been responsive
to the Staff's comments and look forward to resolving any outstanding issues as quickly as possible. Please direct any questions
or comments regarding the foregoing to me at (212) 735-2512 or jon.hlafter@skadden.com or Todd Freed at (212) 735-3714 or todd.freed@skadden.com.

 Very truly yours,

 /s/ Jon A. Hlafter

 Jon A. Hlafter

 cc: Jennifer Leyden, Senior Vice President and Chief Financial Officer, Getty Images Holdings, Inc.

 Kjelti Kellough, Senior Vice President, General Counsel and
Corporate Secretary, Getty Images Holdings, Inc.

 Todd E. Freed, Skadden, Arps, Slate, Meagher & Flom LLP

 Ryan J. Dzierniejko, Skadden, Arps, Slate, Meagher &
Flom LLP