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 March 12, 2025

James Peck
Chief Executive Officer
NIQ Global Intelligence Limited
200 West Jackson Boulevard
Chicago, IL 60606

 Re: NIQ Global Intelligence Limited
 Draft Registration Statement on Form S-1
 Submitted February 12, 2025
 CIK No. 0002054696
Dear James Peck:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1
Prospectus Summary, page 1

1. Please disclose the material terms of the Shareholders' Agreement that
you intend to
 enter into in connection with this offering. Identify the parties and
the rights of each of
 the parties under the agreement including but not limited to, the
consent rights in
 connection with certain corporate transactions and board representation.
Also include
 a risk factor regarding any uncertainties and the impact of the
Shareholders'
 Agreement on the company.
2. Please revise the ownership chart to indicate where the registrant is
represented in the
 organizational structure. Identify the entities that are included in
each group of
 "operating subsidiaries." We note references to Nielson Consumer LLC and
The
 Nielson Company (Europe) but it is unclear how they relate to the
companies in the
 March 12, 2025
Page 2

 chart. Finally, clarify the relationship between Grace Holdco GmbH and
Gfk GmbH
 and why it is represented by a jagged line.
3. Please disclose whether you intend to rely on the controlled company
 exemptions under the applicable listing rules.
Risk Factors
We face risks related to sales to government entities, page 30

4. So that we may better understand the potential significance of this
risk, please
 quantify for us the amount of revenue generated during the periods
presented from
 your contracts with the U.S. federal government. Please also tell us the
expected
 future revenues that you anticipate from any signed multi-year
arrangements with the
 U.S. federal government.
Use of Proceeds, page 62

5. To the extent known, please disclose the portion of the offering
proceeds that will be
 used to repay the amounts outstanding under the Term Loan Facilities
under the
 Credit Agreement.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Company Overview, page 68

6. We note your use of the defined term "highly reoccurring revenue" to
describe
 revenue derived from the sale of Activation solutions. It is unclear
what threshold is
 being used to differentiate these revenues as "highly reoccurring"
compared to other
 reoccurring revenue streams. Please advise or revise accordingly.
Key Performance Metrics, page 73

7. You indicate on page 74 that your calculation of Net Dollar Retention
(NDR) does not
 include the impact of revenue increases from acquiring new clients
during the period.
 However, you seem to disclose on page 73 that Subscription Revenue and
Annualized
 Revenue (which appears to be used in the calculation of NDR) include
annualized
 revenue associated with the GfK Combination as if it occurred at the
beginning of the
 applicable reported period. Please tell us how the calculation of your
key performance
 metrics for 2022 would have been impacted if GfK annualized revenue was
excluded
 for that period.
Segment Results, page 80

8. Please revise references to Revenues, Adjusted EBITDA and Adjusted
EBITDA
 Margin throughout this section to include the word "Segment" or refer to
the specific
 segment name so that they are differentiated from GAAP revenues,
non-GAAP
 Adjusted EBITDA and non-GAAP Adjusted EBITDA Margin as described
beginning
 on page 87.
9. In your discussion of changes in Adjusted EBITDA and Adjusted EBITDA
margin for
 the Americas and EMEA segments, you indicate that the increases are
primarily
 attributable to the GfK Combination along with Pro Forma Organic
Constant
 Currency Revenue Growth. Based upon your description of this term on
page 85, it
 March 12, 2025
Page 3

 appears some aspects of Pro Forma Organic Constant Currency Revenue
Growth are
 already captured in the increase attributable to the GfK Combination.
Please revise to
 quantify the impact of each factor separately and in your response,
please tell us how
 you are able to determine the distinct impact of both factors.
Supplemental Unaudited Pro Forma Combined Financial Information, page 81

10. We note the disclosure of your pro forma results of operations in the
table on page 82.
 Please provide pro forma financial statements that fully comply with the
guidance
 in Article 11 of Regulation S-X, consistent with what your pro forma
disclosure
 obligation would have been had a registration statement been filed at
the time of the
 acquisition.
Non-GAAP Financial Measures
EBITDA, Adjusted EBITDA, and Adjusted EBITDA Margin, page 87

11. Please tell us how you considered if your adjustment for nonoperating
items, net
 should also include gains from remeasurement of previously held equity
interests for
 all periods presented. Refer to Question 100.03 of the Compliance and
Disclosure
 Interpretations on Non-GAAP Financial Measures.
Liquidity and Capital Resources, page 97

12. For each significant asset or liability that is currently priced based
on reference to
 Euro LIBOR, clarify whether you have evaluated whether the contractual
language
 will permit conversion to a new reference rate.
Critical Accounting Estimates, page 100

13. To provide greater context to investors, please revise to quantify the
amount of
 revenue recognized in connection with cooperation agreements during the
periods
 presented.
Business
Our NIQ Ecosystem, page 111

14. Please revise to clarify how revenues generated from clients using your
solutions
 (NIQ Intelligence, NIQ Your Way and NIQ The Full View) correlate to your
 Intelligence and Activation product groupings.
Principal Shareholders, page 159

15. For each entity listed in the beneficial ownership table, including
Advent Shareholder
 and NIM, identify the natural person(s) with voting and/or dispositive
control over the
 shares held by it.
Consolidated Financial Statements
1. Organization and Description of Business, page F-10

16. Please revise to identify and define the "Parent" as used in these
financial statements.
 March 12, 2025
Page 4
3. Acquisitions, page F-17

17. We note your disclosure on page F-20 regarding the nature of the
adjustments
 reflected in your unaudited pro forma financial information. Please
revise to also
 disclose the amount of any material, nonrecurring pro forma adjustments
directly
 attributable to the business combination. Refer to ASC
805-10-50-2(h)(4).
18. We note you acquired GfK on July 10, 2023. Please provide audited
financial
 statements of GfK pursuant to Rule 3-05 of Regulation S-X and provide us
your
 analysis, including your tests of significance. In this regard, note the
periods presented
 may be adjusted for the post-acquisition periods covered in your audited
financial
 statements.
6. Goodwill and Intangible Assets, page F-23

19. On pages F-44 and F-47, you indicate that changes to your reporting
structure during
 2024 resulted in the identification of new reporting units, operating
segments and
 reportable segments. Please revise so that your disclosures reflect how
goodwill has
 been reallocated to your new reportable segments for all periods
presented. Refer to
 ASC 280-10-50-34.
16. Share-Based Compensation, page F-43

20. You disclose that under your share-based compensation plan, units or
shares "may be
 issued in the form of incentive condition Class B, Class C, Class D or
Class E shares
 of an indirect Parent of the Company." Please revise to clarify what is
meant
 by "incentive conditioned" shares. Please also revise to identify the
indirect Parent of
 the Company.
18. Nonoperating (Expense) Income, Net, page F-46

21. Please tell us how you determined that factoring fees should be included
within non-
 operating expenses. We note in your disclosure on page F-12 that you
record proceeds
 from the sales of accounts receivables as operating activities in your
Consolidated
 Statements of Cash Flows.
Signatures, page II-6

22. Please confirm that the registration statement will be signed by an
authorized
 representative in the United States given that the registrant is
incorporated in Ireland.
General

23. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.
 March 12, 2025
Page 5

 Please contact Lisa Etheredge at 202-551-3424 or Robert Littlepage at
202-551-3361
if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Jan Woo at
202-551-3453 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Thomas Fraser
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