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 July 21, 2025

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

 Re: NIQ Global Intelligence Limited
 Amendment No. 1 to Registration Statement on Form S-1
 Filed July 14, 2025
 File No. 333-288376
Dear James Peck:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Amendment No. 1 to Registration Statement on Form S-1
Summary Historical Consolidated Financial Data
Recent Developments, page 30

1. Please revise your bullet pointed list on page 31 to include your
preliminary estimate
 of net loss attributable to NIQ for the three months ended June 30,
2025. This bullet
 point should appear before your Adjusted EBITDA estimate for the same
period.
 Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
2. Please revise your discussion of footnote 5 on page 32 to explain the
specific
 reason(s) for $57 million in estimated foreign currency exchange gains
for the three
 months ended June 30, 2025. We note that this adjustment was minimal
during the
 three months ended June 30, 2024.
 July 21, 2025
Page 2
Capitalization, page 75

3. Please revise to include a pro forma column that gives effect to the
Reorganization,
 separate from the offering. The pro forma financial information provided
should be
 presented in a manner consistent with Article 11 of Regulation S-X.
4. In footnote 2 on page 76, you indicate that the capitalization table
does not reflect any
 repayment of borrowings with proceeds from the offering. However, we
note that the
 revolver line item reflects a zero balance in the "as adjusted" column
as of March 31,
 2025. Please refer to Rule 11-02(b)(8) and advise or revise accordingly.
5. Please revise footnotes 3 and 4 to provide a more fulsome description of
the
 adjustments to recognize a Warrant Liability and Phantom Liability. Your
revised
 disclosures should explain how these amounts were calculated and how
they are
 directly related to the offering. As a related matter, please tell us
how you determined
 that no liability was needed for phantom awards and the warrant
agreement for
 periods prior to the offering.
Supplemental Unaudited Pro Forma Combined Financial Information, page 102

6. Regarding the Reorganization, we note on page 213 that prior to the
completion of
 this offering your authorized share capital will be $15,000 and
25,000, divided into
 1,500,000,000 ordinary shares with a nominal value of $0.00001 per
share,
 150,000,000 Preferred Shares with a nominal value of $0.00001 per share
and 25,000
 Euro deferred shares with a nominal value of 1.00 per share. Since it
appears this
 reorganization will materially impact stockholders' equity and EPS
related disclosures,
 please provide pro forma financial statements prepared in accordance
with Article 11
 of Regulation S-X, pursuant to Rule 11-01(a)(8) of Regulation S-X. Also,
clearly
 disclose within the pro forma information, and elsewhere where you
disclose the
 reorganization, the share split ratio the will be effected as part of
the Reorganization.
Management's Discussion and Analysis
Liquidity and Capital Resources, page 128

7. We note the adjustment in your capitalization table on page 75 for
warrant and
 phantom liabilities totaling nearly $114 million. Please revise your
MD&A here or
 elsewhere as applicable to address how the warrant agreement and phantom
awards
 are reasonably expected to impact your cash obligations and results of
operations in
 future periods.
Consolidated Financial Statements, page F-1

8. We note the registrant has been incorporated since June 6, 2017 and it
has had "no
 business transactions or activities to date." Since NIQ Global
Intelligence
 plc will succeed to a business for which financial statements are
required to be
 included in this filing, please include the financial statements of the
registrant.
9. Please explain to us why, prior to the reorganization, you report in the
Intermediate
 Dutch Holdings B.V. Consolidated Statements of Operations "Net loss
attributable to
 NIQ" and in the Intermediate Dutch Holdings B.V. Consolidated Balance
Sheets you
 report "Total NIQ stockholders equity."
 July 21, 2025
Page 3

Note 16. Share-Based Compensation, page F-46

10. Please provide a summary of share-based awards granted since January 1,
2024.
 Provide the date and amount of each share-based award granted along with
estimated
 fair value of the underlying shares of common stock. Reconcile and
explain the
 differences between the fair values determined on each grant date
including the
 difference between the most recent grant date fair value and the
midpoint of your
 offering range. This reconciliation should describe significant
intervening events
 within the company and changes in assumptions with the valuation
methodologies
 employed that explain the changes in fair value of your common stock up
to the filing
 of the registration statement.
General

11. We note that the reorganization will not be completed until after
effectiveness. With a
 view to disclosure, please advise us of the timing of the steps of the
reorganization
 and confirm whether the reorganization is a condition to closing the
offering.
 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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