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Paul, Weiss, Rifkind, Wharton & Garrison
LLP

1285 Avenue of the Americas

New York, New York 10019-6064

January 24, 2025

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.

                                            Registration Statement on Form 10-12B

                                            Filed December 30, 2024

                                            File No. 001-42458

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 Amendment No. 1 (“Amendment No. 1”) to the Registration Statement on Form 10 for the
Company’s common stock (the “Registration Statement”), together with exhibits, as filed with the Securities
and Exchange Commission (the “Commission”) on December 30, 2024.

Amendment No. 1 reflects the responses of
the Company to comments received in a letter from the Staff of the Commission (the “Staff”), dated January 21,
2025 (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. Capitalized terms that are not defined herein have the meanings given to them
in the information statement filed as Exhibit 99.1 to Amendment No. 1 (the “Information Statement”).

Securities
and Exchange Commission

Division of Corporation Finance

January 24, 2025

Page 2

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

Form 10-12B

Exhibit 99.1 - Preliminary Information Statement

Unaudited Pro Forma Condensed Consolidated Financial Statements

Notes to the Unaudited Pro Forma Condensed Consolidated Financial
Statements

Note 2. Autonomous Entity Adjustments, page 52

 1. We
                                            note that the amounts presented in your pro forma statements of operations for the Management
                                            Fee in adjustment (h) are based on the amounts that will be billed in each respective
                                            period. Please tell us your consideration for including pro forma adjustments for the Management
                                            Fee that ultimately will be paid based on results each period. In this regard, since your
                                            Management Fee is based on a trailing twelve month calculation, for example, the $860,000
                                            fee associated with the third quarter of 2024 (i.e., $34.4 million Management Agreement Adjusted
                                            EBITDA times 2.5%) will be included in the payment associated with each quarter through the
                                            second quarter of 2025. In other words, explain to us why at September 30, 2024 there
                                            is no accrued Management Fee for the sum of 7.5% of the Adjusted EBITDA for the third quarter
                                            of 2024 plus 5% of the Adjusted EBITDA for the second quarter of 2024 plus $2.5% of the Adjusted
                                            EBITDA for the first quarter of 2024.

The Company respectfully
acknowledges the Staff’s comment. The Company respectfully advises the Staff that per Section 3220.2 of the Division of Corporation
Finance Financial Reporting Manual (the “Financial Reporting Manual”), pro forma adjustments for the balance sheet “should
be computed assuming the transaction was consummated on the date of the latest balance sheet included in the filing.” September
30, 2024 is the date of the latest balance sheet included in the filing, and accordingly is the date on which the Pro Forma Transactions
are assumed to have been completed for purposes of the pro forma financial information. Had the Pro Forma Transactions been consummated
on September 30, 2024, the CompoSecure Management Agreement would have been signed on that date and no fees would have been accrued at
that time. For completeness, Section 3230 of the Financial Reporting Manual provides guidance for adjustments to the pro forma income
statement. In particular, Section 3230.3 indicates that pro forma adjustments to the income statement “should be computed assuming
the transaction occurred at the beginning of the fiscal year presented and carried forward through any interim period presented.”
Applying this assumption, the CompoSecure Management Agreement would have been effective during the twelve months ended December 31, 2023
and the nine months ended September 30, 2024, and accordingly, the related expense has been included in the pro forma income statements
for these periods.

Section 3 of the CompoSecure
Management Agreement defines the services to be performed by the Company thereunder, and Section 7 of the CompoSecure Management Agreement
provides for the payment by CompoSecure Holdings, L.L.C. ("CompoSecure Holdings") of quarterly Management Fees. Section 7 of the CompoSecure Management Agreement also
states that “the Manager will not receive any Quarterly Management Fees prior to the Effective Date,” and accordingly,
the Company will not receive any Management Fees prior to the effectiveness of the CompoSecure Management Agreement at the time of the
completion of the Spin-Off. Pursuant to the CompoSecure Management Agreement, Management Fees are prorated for any partial periods.

In addition to considering
the appropriate presentation of the pro forma information in the Information Statement, the Company and CompoSecure Holdings  have considered how the Management Fees will be treated in the financial statements of the Company and CompoSecure Holdings,
respectively, on an ongoing basis. Under ASC 606, the Company has performance obligations to perform the services defined in Section 3
of the CompoSecure Management Agreement. The completion of those obligations will result in the payment of the Management Fees contemplated
by Section 7 of the Management Agreement. The Company believes that the performance obligation will be fulfilled as management services
are performed during each quarter. There is symmetry between the timing of revenue recognition at Resolute Holdings and the expense incurrence
at CompoSecure Holdings. Accordingly, on an ongoing basis, the Company and CompoSecure Holdings intend to recognize revenue and expense
at the same time as services under the CompoSecure Management Agreement are performed or received.

General

 2. We
                                            note that you list many "forms of" exhibits. To the extent the executed version
                                            of an exhibit is available prior to effectiveness of the Form 10, please file the final
                                            version of that exhibit.

The Company respectfully
acknowledges the Staff’s comment and will file executed copies of agreements where applicable. The Company does not currently expect
that any of the “forms of” listed as exhibits to the Registration Statement will be executed prior to effectiveness. The Company
expects that the Amended and Restated Certificate of Incorporation and the Amended and Restated Bylaws of the Company will each become
effective, in the forms currently filed as Exhibits 3.1 and 3.2, respectively, to the Registration Statement, following effectiveness
of the Registration Statement and on or before the Distribution Date.

* * *

Securities
and Exchange Commission

Division of Corporation Finance

January 24, 2025

Page 3

If
you have any questions regarding the Registration Statement, Amendment No.1 and the Information Statement, please do not hesitate to
contact the undersigned at (212) 373-3025 or jkennedy@paulweiss.com or Steven J. Feder, General Counsel of CompoSecure, Inc.
at (610) 357-1574 or sfeder@composecure.com.

    Sincerely,

    /s/ John C. Kennedy

    John C. Kennedy

 cc: Jon C. Wilk

    Timothy W. Fitzsimmons

    CompoSecure, Inc.