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Correspondence 0001628280-24-017716 from Getty Images Holdings, Inc. (GETY)

Getty Images Holdings, Inc.
Date: April 24, 2024 · CIK: 0001898496 · Accession: 0001628280-24-017716

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File numbers found in text: 333-278454

Date
April 24, 2024
Author
Kjelti Kellough
Form
CORRESP
Company
Getty Images Holdings, Inc.

Letter

Document

Getty Images Holdings, Inc.

605 5th Ave S., Suite 400

Seattle, Washington 98104

April 24, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

Re: Getty Images Holdings, Inc.

Registration Statement on Form S-3

Filed April 2, 2024

File No. 333-278454

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Getty Images Holdings, Inc. (the “Company”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-referenced Registration Statement on Form S-3 to become effective on April 26, 2024, at 4:00 p.m., Eastern Time, or as soon as practicable thereafter.

The Company hereby authorizes Heather Emmel of Weil, Gotshal & Manges LLP, counsel to the Company, to orally modify or withdraw this request for acceleration.

The Company requests that it be notified of such effectiveness by a telephone call to Heather Emmel of Weil, Gotshal & Manges LLP at (212) 310 8849.

Very truly yours,
GETTY IMAGES HOLDINGS, INC.

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CORRESP
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Document

Getty Images Holdings, Inc.

605 5th Ave S., Suite 400

Seattle, Washington 98104

April 24, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

Re: Getty Images Holdings, Inc.

Registration Statement on Form S-3

Filed April 2, 2024

File No. 333-278454

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Getty Images Holdings, Inc. (the “Company”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) take appropriate action to declare the above-referenced Registration Statement on Form S-3 to become effective on April 26, 2024, at 4:00 p.m., Eastern Time, or as soon as practicable thereafter.

The Company hereby authorizes Heather Emmel of Weil, Gotshal & Manges LLP, counsel to the Company, to orally modify or withdraw this request for acceleration.

The Company requests that it be notified of such effectiveness by a telephone call to Heather Emmel of Weil, Gotshal & Manges LLP at (212) 310 8849.

Very truly yours,

GETTY IMAGES HOLDINGS, INC.

By:

 /s/ Kjelti Kellough

Name: Kjelti Kellough

Title: Senior Vice President, General Counsel and Secretary

cc: Heather Emmel, Weil, Gotshal & Manges LLP

Sakshi Sharma, Weil, Gotshal & Manges LLP

Tina Tang, Weil, Gotshal & Manges LLP