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Paul, Weiss, Rifkind, Wharton & Garrison
LLP

1285 Avenue of the Americas

New York, New York 10019-6064

December 30, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 Attention: Mark Brunhofer, Jason Niethamer, David Gessert and J. Nolan McWilliams

                                            Division of Corporation Finance

                                            Office of Crypto Assets

 Re: Resolute Holdings Management, Inc.

                                            Draft Registration Statement on Form 10

                                            Submitted October 4, 2024

                                            CIK No. 0002039497

Dear Sirs:

On behalf of Resolute Holdings Management, Inc.,
a Delaware corporation (the “Company” or “Resolute Holdings”), we hereby submit in electronic form
the accompanying Registration Statement on Form 10 for the Company’s common stock (the “Registration Statement”),
together with exhibits, as originally confidentially submitted to the Securities and Exchange Commission (the “Commission”)
on October 4, 2024 (the “Initial Registration Statement”).

The Registration Statement reflects the responses
of the Company to comments received in a letter from the Staff of the Commission (the “Staff”), dated November 5,
2024 (the “Comment Letter”), and the inclusion of certain other information. The discussion below is presented in
the order of the numbered comments in the Comment Letter. All references to page numbers in our responses are to the pages of
the information statement filed as Exhibit 99.1 (the “Information Statement”) to the Registration Statement.

Securities
and Exchange Commission

Division of Corporation Finance

December 30, 2024

Page 2

The Company respectfully submits the following
as its responses to the Staff:

Draft Registration Statement on Form 10

Exhibit 99.1 - Preliminary Information Statement Information

Statement Summary

Our Business, page 1

 1. Please
                                            balance this section by disclosing the lack of Resolute Holdings’ historical and performance
                                            data and that it is expected to initially operate with limited profitability because of the
                                            initial resource investment required to build its capabilities.

In response to
the Staff’s comment, the Company has revised its disclosure on page 1 of the Information Statement.

 2. Please
                                            briefly substantiate your statement in the second paragraph of this section that Mr. Cote
                                            is responsible for “delivering” the increase in Vertiv’s share price during
                                            his term as chairman of the board.

In response to
the Staff’s comment, the Company has revised its disclosure on pages 1 and 54 of the Information Statement.

 3. Refer
                                            to the third paragraph. Please briefly disclose in what ways you aspire to be an “industry
                                            leading” operations manager.

In response to
the Staff’s comment, the Company has revised its disclosure on pages 1 and 54 of the Information Statement.

Risk Factors

Regulatory changes or actions may restrict the use, page 21

 4. We
                                            note statements throughout this risk factor regarding “legal uncertainty” concerning
                                            crypto assets and that federal regulators and the courts “are still developing their
                                            frameworks” concerning crypto assets. This disclosure is not appropriate considering
                                            well-established legal tests in U.S. Supreme Court case law and Commission and staff reports,
                                            orders, and statements providing guidance on when a crypto asset may be offered and sold
                                            as a “security” under the U.S. federal securities laws. Please revise your risk
                                            factor discussion accordingly.

In response to
the Staff’s comment, the Company has revised its disclosure on pages 21-24 of the Information Statement.

If tariffs and other restrictions, page 27

 5. Please
                                            place this risk factor in context by quantifying, to the extent material, the impact of tariffs
                                            on CompoSecure revenues and results of operations.

In response to
the Staff’s comment, the Company has revised its disclosure on page 27 of the Information Statement.

Securities
and Exchange Commission

Division of Corporation Finance

December 30, 2024

Page 3

Following the Spin-Off, we could incur substantial additional costs,
page 34

 6. Please
                                            quantify the accrued and anticipated costs to implement the IT and other infrastructure described
                                            in this risk factor.

In response to
the Staff’s comment, the Company has revised its disclosure on page 35 of the Information Statement.

Unaudited Pro Forma Condensed Consolidated Financial Statements

Notes to Unaudited Pro Forma Condensed Consolidated Financial Statements

Note 1: Basis of Presentation, page 50

 7. Please
                                            provide us your detailed analysis supporting your assertion that Resolute Holdings is required
                                            to consolidate the financial statements of CompoSecure under U.S. GAAP after the contemplated
                                            spin-off transaction. In your response, please reference for us the specific provisions of
                                            the authoritative literature you used to support your position.

The Company respectfully
advises that Staff that, as discussed with the Staff of the Commission, following the filing of the Initial Registration Statement, the
Company revised the structure of the transactions proposed to be undertaken in connection with the Company’s spin-off from CompoSecure, Inc.
(“CompoSecure”), including such that the counterparty to the Company’s Management Agreement would be CompoSecure Holdings,
L.L.C. (“CompoSecure Holdings”), a direct, wholly owned subsidiary of CompoSecure, and not CompoSecure itself.

Following that
change, the Company discussed the Company’s conclusions regarding the appropriate accounting with respect to the CompoSecure Management
Agreement with the Staff, the Company’s independent registered public accounting firm, and its external accounting advisor. Based
on the facts and circumstances in effect at the time of filing the Information Statement, the Company believes that the interest that
the Company will acquire in CompoSecure Holdings in connection with the spin-off, which immediately following the spin-off will be the
Company’s sole management agreement, constitutes a variable interest pursuant to ASC 810-10-55-37, and accordingly, the Company
must consolidate the financial results of CompoSecure Holdings in the Information Statement.

The Business of CompoSecure

 Consumer Products, page 66

 8. We
                                            note your disclosure regarding the security of the Arculus Cold Storage Wallet. Please discuss
                                            the extent to which the firmware and hardware underlying the Arculus Cold Storage Wallet
                                            is subject to internal or third party security audits.

The Company, on
behalf of CompoSecure, respectfully advises the Staff that the Arculus Cold Storage Wallet is subject to internal testing with every
software release and update.  In addition, CompoSecure has previously completed three security audits conducted by external third
parties: an audit by Stratum Security in 2021, an audit by Halborn in 2024, and a SOC II review in 2023 by Kirkpatrick Price. Kirkpatrick
Price is also currently conducting an additional SOC II review with respect to CompoSecure’s software development processes.

Securities
and Exchange Commission

Division of Corporation Finance

December 30, 2024

Page 4

We
respectfully submit on behalf of CompoSecure that the foregoing information provided in response to the Staff’s comment is not
material to CompoSecure, and that the extent, depth and content of the existing disclosures regarding the Arculus Cold Storage Wallet
are appropriate given that the net revenues from Arculus service offerings comprised less than 1% of CompoSecure’s total net sales
in 2023, and accordingly have been, and are currently expected to continue to be, immaterial to CompoSecure’s overall business,
results of operations, and financial condition for the foreseeable future. To the extent the consumer products business becomes material
to CompoSecure in the future, we and CompoSecure would revisit the level of information contained in our and its respective public filings
regarding the Arculus Cold Storage Wallet.

 9. Refer
                                            to the last full paragraph on page 66. Please tell us the specific digital assets currently
                                            supported by the Arculus Cold Storage Wallet. Also discuss in greater detail the scope and
                                            timeframe to increase the number and type of digital assets supported.

The Company, on
behalf of CompoSecure, respectfully advises the Staff that the Arculus Cold Storage Wallet provides a different type of support depending
on the type of digital asset. Decisions as to what level of support is provided for which digital assets is subject to applicable securities
laws and other legal analyses specific to the type of support, which CompoSecure re-evaluates from time to time including as a result
of legal and regulatory developments and other considerations, including requests from Arculus Cold Storage Wallet customers.

For
a broad range of digital assets, the Arculus Cold Storage Wallet provides “store/view/send/receive” support, meaning that
customers who own such digital assets may store and view such digital assets in their respective wallets, and may send and receive such
digital assets. The Arculus Cold Storage Wallet does not charge or otherwise receive any fees for “store/view/send/receive”
support. For a significantly more limited universe of digital assets, the Arculus Cold Storage Wallet incrementally provides “purchase/swap”
support, which consists solely of providing links to access third-party liquidity providers. See the Company’s response to the
Staff’s comment number 10 below for additional information. CompoSecure makes available on the public website for the Arculus Cold
Storage Wallet a list of certain key blockchains/digital assets that are supported by the Arculus Cold Storage Wallet. The list is available
at https://www.getarculus.com/coin-support/, and its contents are subject to change from time to time. The list sets forth
the complete set of digital assets for which Arculus Cold Storage Wallet provides “purchase/swap” support, but is only a
representative sample of the digital assets supported for the more limited “store/view/send/receive” level of support, as
the full list would contain thousands of digital asset types and would be impracticable for CompoSecure to maintain accurately, particularly
as new tokens may be created on many blockchains without action by or the knowledge of CompoSecure.

The Arculus Cold
Storage Wallet has in the past and may in the future add support for additional blockchains, which requires that the hardware component
(i.e., the metal Arculus card) support the cryptography of the new blockchain. Assuming the Arculus card can support the new blockchain,
the Arculus Cold Storage Wallet is able to add support for such blockchains by modifying the software component (i.e., the Arculus
mobile app) typically in an update or new release. Therefore, the work and time involved to add support for a new blockchain can vary
considerably depending on the specific structure and complexity of the new blockchain in question, but in CompoSecure’s experience
typically takes between four and eight weeks. CompoSecure currently makes determinations whether to add support for new blockchains based
on multiple criteria, including customer requests, market capitalization and volume of activity of the blockchains, as well as opportunities
for strategic partnerships.

Securities
and Exchange Commission

Division of Corporation Finance

December 30, 2024

Page 5

We
respectfully submit on behalf of CompoSecure that the foregoing information provided in response to the Staff’s comment is not
material to CompoSecure, and that the extent, depth and content of the existing disclosures regarding the Arculus Cold Storage Wallet
are appropriate given that the net revenues from Arculus service offerings comprised less than 1% of CompoSecure’s total net sales
in 2023, and accordingly have been, and are currently expected to continue to be, immaterial to CompoSecure’s overall business,
results of operations, and financial condition for the foreseeable future. To the extent the consumer products business becomes material
to CompoSecure in the future, we and CompoSecure would revisit the level of information contained in our and its respective public filings
regarding the Arculus Cold Storage Wallet.

 10. Refer
                                            to the first full paragraph on page 67. Please identify the third-party liquidity providers
                                            with whom you have arrangements and briefly describe the criteria you consider when determining
                                            to engage an additional liquidity provider.

The
Company, on behalf of CompoSecure, respectfully advises the Staff that the Arculus Cold Storage Wallet presently makes available
links to the following three liquidity providers: Onramper, which is an onramp aggregator (for fiat-to-crypto transfers); Changelly (for
crypto-to-crypto transactions); and Transak (for crypto-to-fiat transactions). All fiat-to-crypto, crypto-to-crypto and crypto-to-fiat
transactions are conducted solely by the respective foregoing liquidity provider. The Arculus Cold Storage Wallet does not charge its
customers any fees for “purchase/swap” activities or for accessing third-party liquidity providers, but CompoSecure may receive
a small portion of the fees charged by some third-party liquidity partners. Additionally, the Arculus Cold Storage Wallet also provides
a link to WalletConnect, a portal to other web-based transaction support and liquidity providers (but which is not itself a liquidity
provider). The Arculus Cold Storage Wallet does not charge any fees to access WalletConnect, and does not receive any fees from activity
conducted through web-based transactions and liquidity providers accessed through WalletConnect.

CompoSecure selects
its liquidity providers based on a range of criteria, including global coverage, fees, execution quality, ease of integration, reputation,
and reliability. CompoSecure re-evaluates these criteria from time to time as appropriate, including as a result of legal and regulatory
developments, and other considerations. CompoSecure does not itself actively trade in crypto on its own behalf or on behalf of any other
person or entity, other than in a de minimis amount for its own account, primarily for demonstration purposes. Subject to that
de minimis exception, CompoSecure does not actively engage in transactions with liquidity providers beyond making available the
links to customers. Any activity between Arculus