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CORRESP

 +1 617 526 6000 (t)

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 wilmerhale.com

 September 4, 2024

 Via EDGAR Submission

United States Securities and Exchange Commission

 Division of
Corporation Finance – Office of Technology

 100 F Street, N.E.

Washington, D.C. 20549

Attn:
 Chen Chen

Kathleen Collins

 Aliya
Ishmukhamedova

 Mitchell Austin

Re:
 Toro CombineCo, Inc.

Registration Statement on Form S-4

Filed June 27, 2024

 File No. 333-280529

 Ladies and Gentlemen:

This letter is being submitted on behalf of Toro CombineCo, Inc. (“Toro”) in response to the comments of the staff (the “Staff”) of the
Office of Technology of the Division of Corporation Finance of the United States Securities and Exchange Commission with respect to Toro’s Registration Statement on Form S-4, filed on June 27, 2024
(the “Registration Statement”), as set forth in the Staff’s letter dated July 24, 2024 to Michael Cotoia, Chief Executive Officer of Toro (this “Comment Letter”). Toro is concurrently filing its Amendment No. 1 to
the Registration Statement (the “Amended Registration Statement”), which includes changes to reflect responses to the Staff’s comments and other updates.

For reference purposes, the text of the Comment Letter has been reproduced in bolded and italicized font herein with Toro’s response below each numbered
comment. Unless otherwise indicated, the page references in the Staff’s comments refer to the Registration Statement, and the page references in Toro’s responses refer to the Amended Registration Statement. Where appropriate, Toro has
responded to the Staff’s comments by making changes to the disclosure in the Amended Registration Statement. All capitalized terms used and not otherwise defined herein shall have the meanings set forth in the Amended Registration Statement.
The response provided herein is based upon information provided to Wilmer Cutler Pickering Hale and Dorr LLP by or on behalf of Toro.

 On behalf of Toro, we advise you as follows:

Registration Statement on Form S-4

Voting by TechTarget Directors and Executive Officers, page 90

1.
 Please include the disclosure required by Item 3(h) of Form
S-4.

 Response: We acknowledge the Staff’s comment and
confirm that Toro will populate the information regarding the number of shares of TechTarget, Inc. (“TechTarget”) common stock, par value $0.001 (“common stock”), beneficially owned by TechTarget’s directors and executive
officers and their affiliates once the record date has been determined. We further note that the applicable vote required to approve the Transactions is provided in the paragraphs that precede such information and that Toro’s directors and
executive officers are officers of TechTarget.

 Background of the Transactions, page 98

2.
 Please expand your disclosures regarding the background of the transaction to include:

•

 any discussions with Informa about the potential loss of clients in the near future or any other events
that may materially affect the NewCo prospects or its financial projections for future performance of the business;

•

 any discussions relating to the assumptions underlying any target projections;

•

 whether there were any valuations or other material information about the companies involved in this
transaction provided to potential investors that have not been disclosed publicly;

•

 the negotiation of any contingent payments to be received by target shareholders; and

•

 the negotiation of any arrangements whereby any shareholder agrees to waive its redemption rights.

 Response: We respectfully advise the Staff that Toro has revised the disclosure starting on page 106 of the
Amended Registration Statement in response to the Staff’s comment. We further respectfully advise the Staff that to the extent the revised disclosure does not address one of the topics enumerated in the Staff’s comment, no material
developments or events took place prior to execution of the Transaction Agreement with respect to such topics and therefore no disclosure has been added to the Amended Registration Statement.

Projected Financial Data, page 120

3.
 We note your disclosure that “the Forecasts reflect numerous estimates and assumptions made by the
management.” Please include here a summary of key assumptions. Also, to the extent your forecasts reflect more than simple growth rates, explain why these rates are reasonable and disclose the limitations presented by the difficulty in
sustaining significant growth rates over a long period of time. Please refer to Items 10(b)(2) and (b)(3)(i) of Regulation S-K.

Response: We respectfully advise the Staff that Toro has revised the disclosure starting on page 124 of the Amended Registration
Statement in response to the Staff’s comment.

 U.S. Federal Income Tax Consequences of the Transactions, page 145

4.
 We note your disclosure that for U.S. federal income tax purposes, the Transactions are intended to
constitute a transaction that is described in Section 351 of the Internal Revenue Code. If you believe the Transactions qualify as a transaction that is described in Section 351 of
the IRC, please file a legal opinion supporting such a conclusion. Alternatively, revise your current disclosure, both here and elsewhere, to first make clear that it is uncertain whether the Transactions will qualify as a
Section 351 transaction and then discuss the potential consequences to shareholders if the Transactions: (1) do not qualify as a Section 351
transaction; and (2) qualify as a Section 351 transaction. Additionally, please revise to clearly and plainly state what a transaction described in
Section 351 of the IRC is.

 Response: We respectfully advise the Staff
that Toro has revised the disclosure starting on page 146 of the Amended Registration Statement in response to the Staff’s comment. We further advise the Staff that a copy of the tax opinion of Wilmer Cutler Pickering Hale and Dorr LLP has
been filed as Exhibit 8.1 to the Amended Registration Statement.

 Term Loan Credit Facility, page 207

5.
 We note that prior to the closing, you intend to enter into a revolving credit facility or other senior
lending facility. Please revise to provide an update on the status of this plan and clarify whether you intend to enter into this facility prior to the effectiveness of this registration statement.

Response: We respectfully advise the Staff that Toro has revised the disclosure starting on pages 47 and 210 of the Amended
Registration Statement in response to the Staff’s comment.

 Notes to Unaudited Pro Forma Condensed Combined Financial Information

Note 5. Adjustments to Unaudited Pro Forma Condensed Combined Balance Sheet, page 220

6.
 Please explain further the basis for pro forma adjustments 5(i), 6(e) and 7(f). In this regard, you state
that pursuant to the terms of the Transaction Agreement, Informa will assume contingent consideration liabilities. Clarify whether the reference here to Informa is to Informa PLC and if so, tell us why Informa is assuming contingent consideration on
businesses that were contributed as part of the Merger Agreement. Also, tell us where you include a discussion of these terms in the filing and specifically in the Transaction Agreement section beginning on page 162.

Response: We acknowledge the Staff’s comment and respectfully advise the Staff that the contingent consideration liabilities are
comprised of acquisition-related contingent consideration relating to potential revenue growth for Industry Dive and future revenue and cost performance for Canalys, which are further described in Note 5 – Acquisitions pages FS-22 through FS-25 of the Registration Statement, now pages FS-26 through FS-31 of the Amended Registration Statement (collectively, the “Contingent Consideration
Liabilities”). The Contingent Consideration Liabilities are included in the Informa Tech Digital Businesses of Informa PLC Audited Annual Combined Financial Statements because they are a part of the

 Informa Tech Digital Businesses’ liabilities for the historical periods presented and arose from the acquisition of
Industry Dive and Canalys, both of which will become part of Toro as part of the Transactions. However, as part of the negotiation of the Transaction Agreement, Informa PLC (“Informa”) agreed to transfer the Informa Tech Digital Businesses
without the Contingent Consideration Liabilities.

 To memorialize such agreement, the Contingent Consideration Liabilities were included
within the definition of “Ivory Excluded Liabilities” in the Transaction Agreement and will be assigned to an Informa Retained Group member prior to the closing of the Transactions as part of the Separation, which is discussed under the
heading “Informa Tech Digital Businesses Separation Plan” beginning on page 182 of the Registration Statement, now page 184 of the Amended Registration Statement. Specifically, the last paragraph of that section indicates that “(ii)
liabilities related to acquisition or disposition transactions” will not be assumed by Toro as part of Transactions and will instead be transferred to an Informa Retained Group member as part of the Separation.

Rule 11-02(a)(6)(i)(A) of Regulation S-X requires that Toro
calculate the pro forma adjustments using the measurement date and method prescribed by the applicable accounting standards. The applicable measurement date and method for determining whether the liabilities should be recognized on Toro’s
balance sheet is set forth in ASC 805-20-25 and provides in relevant part that “as of the acquisition date, the acquirer shall recognize, separately from
goodwill…. the liabilities assumed…” as part of the transaction. As discussed above, the Contingent Consideration Liabilities will be transferred to an Informa Retained Group member prior to the effectiveness of the registration
statement and therefore will not be a liability of the Informa Tech Digital Business at or after the closing of the Transactions. Rule 11-02(a)(6)(i)(A) of Regulation
S-X and ASC 805-20-25, therefore, require that we eliminate the Contingent Consideration Liabilities from the Pro Forma Condensed
Combined Balance Sheet of Toro as of March 31, 2024, which was accomplished through the proforma adjustment described in footnote 5(i) (such adjustment, the “Pro Forma Balance Sheet Adjustment”).

Rule 11-02(a)(6)(i)(B) of Regulation S-X further requires that
we make adjustments to the Pro Forma Statements of Comprehensive Income of Toro as for the three months ended March 31, 2024 and the year ended December 31, 2023 to give effect to the Pro Forma Balance Sheet Adjustment, assuming those
adjustments were made as of January 1, 2023. Specifically, Rule 11-02(a)(6)(i)(B) of Regulation S-X requires that we eliminate any gain or loss attributable to the
remeasurement of the Contingent Consideration Liabilities during the periods presented, which was accomplished through the proforma adjustments described in footnotes 6(e) and 7(f).

Note 7. Adjustments to the Unaudited Pro Forma Condensed Combined Statements of Income for the Year Ended December 31, 2023, page
225

7.
 Your disclosure on page 165 indicates that the vesting for various TechTarget Incentive Awards (e.g.,
TechTarget Options, Pre-Signing TechTarget RSU, TechTarget RSU) will accelerate upon effectiveness of the Merger. Please tell us how you considered an adjustment to reflect the additional compensation expense
in your pro forma financial statements for the acceleration of these awards, or revise. Refer to Rule 11-02(a)(6)(i)(B) of Regulation S-X.

 Response: We note that Rule 11-02(a)(6)(i)(B) of Regulation S-X and the associated guidance require that we reflect adjustments in the Pro Forma Statements of Comprehensive Income of Toro for the three months ended March 31, 2024 and the year ended December 31,
2023 only if the acceleration of the share-based compensation awards as part of the proposed transactions (the “Applicable Awards”) or the post combination vesting of replacement awards which are not accelerated (the “Replacement
Awards”) is expected to result in Toro incurring compensation expense in excess of the amounts historically incurred by TechTarget during the periods presented.

The compensation expense associated with the acceleration of the Applicable Awards is considered to occur immediately prior to the
consummation of the proposed transactions and, as such, it is not considered to be an expense of Toro. Rather, the shares and cash issued to settle the Applicable Awards are considered to be part of the purchase consideration (as defined in ASC 805-30-30-7) for the proposed transactions. Consistent with the principles underlying Rule
11-02(a)(6)(i)(B) of Regulation S-X, such compensation expense is reflected as having occurred as of January 1, 2023. As such, the acceleration of the Applicable
Awards does not result in additional compensation expense for Toro or any requirement to present a pro forma financial statement adjustment to account for any such compensation expense attributable to Toro in the periods presented.

We additionally considered whether there was any incremental compensation cost associated with the Replacement Awards. During the twelve
months ended December 31, 2023 and three months ended March 31, 2024, the compensation cost historically recorded for the awards that are being replaced with the Replacement Awards was $12.8 million and $3.1 million,
respectively, in the historical TechTarget financial statements. The calculated compensation costs associated with the post close vesting of the Replacement Awards would be $6.7 million and $1.5 million during the twelve months ended
December 31, 2023 and three months ended March 31, 2024, respectively. As such, we determined that the post close vesting of the Replacement Awards resulting from the proposed transactions did not result in any compensation costs that were
incremental to historically recorded amounts during the twelve months ended December 31, 2023 or the three months ended March 31, 2024 periods. Consequently, we did not make any pro forma adjustments to the amounts recorded in the
historical TechTarget financial statements.

8.
 Your adjustment 7(e) states that TechTarget estimates incurring
non-recurring transaction costs of $24,344 thousand related to the Transactions within 12 months from the Closing Date. Please also disclose the amount of transaction costs that are expected to be
incurred by Informa Tech Digital Businesses (the Business), and your consideration to include an adjustment for such costs, if any, in your pro forma financial statements.

Response: We acknowledge the Staff’s comment and respectfully advise the Staff that we have updated the Unaudited Pro Forma
Condensed Combined Statement of Income for the year ended December 31, 2023 to include an adjustment for the estimated non-recurring transaction costs related to the Transaction of $4,470 thousand
expected to be incurred by Informa Tech Digital Businesses within 12 months from the Closing Date. We have also updated the Unaudited Pro Forma Condensed Combined Balance Sheet as of June 30, 2024 to include the same adjustment which is offset
by a capital contribution recorded as additional paid-in capital since Informa plc is assuming this liability on behalf of Informa Tech Digital Businesses. We would also like to note that we have included transaction costs incurred in the six months
ending June 30, 2024 of $26,955 thousand in the Unaudited Interim Condensed Combined Financial Statements of Informa Tech Digital Businesses appearing on page 215 of the Amended Registration Statement.

 Under ASC 805, costs related to the proposed transaction are not part of the allocation of the
consideration transferred. These costs are expensed in the periods in which costs are incurred and the services are received. As noted above, transaction costs of $26,955 thousand related to the Transaction and paid by Informa, h