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CORRESP
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 CORRESP

 ROPES & GRAY LLP PRUDENTIAL TOWER
 800 BOYLSTON STREET BOSTON, MA 02199-3600
 WWW.ROPESGRAY.COM

 July 22, 2025 VIA
EDGAR U.S. Securities and Exchange Commission
 Division of Corporation Finance 100 F Street, N.E.
 Washington, D.C. 20549

 Attention:
 Marion Graham
 Matthew Derby Lisa Etheredge
 Robert Littlepage

 Re:
 NIQ Global Intelligence plc
 Amendment No. 1 to Registration Statement on Form S-1
 Filed July 14, 2025
 CIK No. 0002054696 Ladies and
Gentlemen: On behalf of our client, NIQ Global Intelligence plc (the “Company”), we hereby submit to the Securities and Exchange Commission (the
“Commission”), via EDGAR, an amendment no. 2 to the registration statement on Form S-1 (“Amendment No. 2”). Amendment No. 2 reflects revisions to the Registration Statement
previously filed by the Company with the Commission on June 27, 2025 and amended on July 14, 2025, made in response to the comment letter addressed to the Company dated July 21, 2025 from the staff of the Commission (the
“Staff”). For reference purposes, the comments contained in the Staff’s letter dated July 21, 2025 are reproduced below in bold and
the corresponding responses are shown below the comments. Unless otherwise defined below, terms defined in Amendment No. 2 and used below shall have the meanings given to them in Amendment No. 2.
 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.

 Division of Corporation Finance
 Securities and Exchange Commission July 22, 2025
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 Response to Comment 1:
 In response to the Staff’s comment, the Company has revised the bullet point list as requested.

 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.
 Response to Comment 2: The Company acknowledges the
Staff’s comment and advises that the referenced discussion has been revised to further articulate the nature of the foreign currency exchange gains recorded for the three months ended June 30, 2025 (given the nominal amount recorded for
the three months ended June 30, 2024). One of the Company’s EUR-denominated holding companies holds an approximately $1.1B USD Term Loan. The significant appreciation of the EUR against the USD
between March 31, 2025 and June 30, 2025 (approximately 9%) compared to a nominal decrease of the EUR against the USD between March 31, 2024 and June 30, 2024 (0.7%) primarily explains the net spread of foreign exchange
(gains)/losses reflected in the table between the comparable periods. 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.
 Response to Comment 3: In response to the Staff’s comment,
the Company has revised the capitalization table to include a separate pro forma column reflecting the Reorganization, in addition to the “as further adjusted” column reflecting the offering. The pro forma financial information has been
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 further adjusted” column as of March 31, 2025. Please refer to Rule
 11-02(b)(8) and advise or revise accordingly. Response to Comment 4:
 In response to the Staff’s comment, the Company has revised the presentation of the capitalization table consistent with its response to Comment 3 above,
and in the “as further adjusted” column reflecting the offering (separate from the Reorganization), the Company has revised to reflect the repayment of borrowings with proceeds from the offering.
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 Division of Corporation Finance
 Securities and Exchange Commission July 22, 2025
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 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. Response to Comment 5:
 In response to the Staff’s comment, the Company has revised the footnotes to the capitalization table to explain the Warrant Liability and the Phantom
Liability and, in the case of the Phantom Liability, how it is directly related to the offering. The Warrant Liability is now addressed in the “pro forma” column related to the Reorganization. The Phantom Liability is triggered by the
occurrence of the offering, following which the vesting of the related phantom awards becomes probable to occur; as such, the Phantom Liability is not reflected in periods prior to the offering.
 The Company notes that the Warrant Liability has increased in Amendment No. 2 when compared to Amendment No. 1 because the Company has updated its valuation
methodology for the warrant in conjunction with preparation of the pro forma financial statements included in Amendment No. 2. Such methodology is described within the footnotes to the capitalization table.
 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. Response
to Comment 6: In response to the Staff’s comment, the Company has included pro forma financial statements reflecting the Reorganization in accordance
with Article 11 of Regulation S-X and Rule 11-01(a)(8). The Company
advises the Staff that, prior to the Reorganization, NIQ Global Intelligence plc had 100 ordinary shares outstanding. Following the Reorganization (and prior to this offering), NIQ Global Intelligence plc will have 245,000,000 ordinary shares
outstanding, resulting in an effective share split of 1:2,450,000. The pro forma financial information has been revised to reflect the Reorganization in accordance with Article 11 of Regulation S-X, pursuant
to Rule 11-01(a)(8). The effective share split has been applied retrospectively to all periods presented in the pro forma financial information, including in the calculation of pro forma earnings per share
(EPS). Additionally, the share split ratio and its impact on stockholders’ equity and EPS-related disclosures have been clearly disclosed within the pro forma information and, as appropriate, under the
heading “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.

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 Division of Corporation Finance
 Securities and Exchange Commission July 22, 2025
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 Response to Comment 7:
 In response to the Staff’s comment, the Company has included a discussion of the warrant agreement and the phantom awards and their expected impact in the
Company’s cash obligations and results of operations under the heading “Liquidity and Capital Resources.” The Company notes that the warrant is exercisable for shares and may not be settled in cash.
 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.
 Response to Comment 8: The Company
advises the Staff that NIQ Global Intelligence plc is a business combination related shell company, as contemplated by Section 1160.3 of the Financial Reporting Manual, and therefore, in accordance with Section 1160.1 of the Financial
Reporting Manual, its financial statements may be omitted. As disclosed under the heading “The Reorganization,” prior to the Reorganization,
NIQ Global Intelligence plc had nominal assets and conducted no operations (other than nominal activities incidental to its formation, the Reorganization and this offering). And as contemplated by Rule 165(f) and Rule 145 under the Securities Act,
the Reorganization is being effected through the consent and agreement of each equityholder of AI Pave Dutchco I B.V. to contribute its equity in such entity for equity in NIQ Global Intelligence plc in connection with the Reorganization (and
related redomiciliation) (i.e., in a business combination). Moreover, the Company respectfully submits that, because it has only nominal assets and has
conducted only nominal operations, inclusion of financial statements of NIQ Global Intelligence plc would not provide meaningful additional information to investors.
 In light of the foregoing, the Company has not included the financial statements of NIQ Global Intelligence plc in the Registration Statement. Following this
offering, the Company intends to include the financial statements of NIQ Global Intelligence plc in its periodic reports and other filings as required by applicable law and the rules and regulations of the SEC.

 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.”
 Response to Comment 9: The Company acknowledges the
Staff’s comment and respectfully advises that, under the heading “Basis of Presentation,” the Company discloses the following: “the “Company,” “NielsenIQ,” “NIQ,” the “NIQ group,”
“we,” “us” and “our” means, prior to the Reorganization, Intermediate Dutch Holdings B.V. and its consolidated subsidiaries and, after the Reorganization, NIQ Global Intelligence plc and its consolidated
subsidiaries.” This disclosure is repeated in the introductory paragraphs to the Prospectus Summary. In addition, Note 1 to the Consolidated Financial Statements of Intermediate Dutch Holdings
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 Division of Corporation Finance
 Securities and Exchange Commission July 22, 2025
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B.V. states that Intermediate Dutch Holdings B.V. is referred to, together with the “NIQ subsidiaries” (as therein defined), as “NIQ” or “the Company.”
“NIQ” is also the principal trade name for the Company’s operating business. On that basis, the Company has included references such as “Net Loss attributable to NIQ” and “Total NIQ stockholders’ equity” in
its disclosure, and the Company respectfully submits that the meaning of such disclosure has been made clear to investors. 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. Response to Comment 10:
 In response to the Staff’s comment, the Company has provided the requested summary and reconciliation below. The Company respectfully advises the Staff
that the Company believes that the fair values used as the basis for determining share-based compensation in connection with its profit interest and restricted share unit grants have been reasonable and appropriate for the reasons set forth
below.
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 Division of Corporation Finance
 Securities and Exchange Commission July 22, 2025
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 Equity Awards From January 1, 2024 to July 22, 2025
 Since January 1, 2024, the Board of Directors, with input from management, determined the estimated fair value of the Company’s share-based awards
after considering contemporaneously obtained valuation reports from an independent third-party valuation specialist as well as the other objective and subjective factors described in the Registration Statement under the heading Management’s
Discussion and Analysis of Financial Condition and Results of Operations—Critical Accounting Estimates—Equity Award Valuations.” Below is
a detailed summary of share-based awards granted since January 1, 2024, including grant dates, profit interest amounts and type, estimated grant date fair values and estimated total equity value (which was used to establish the value above
which such profits interests would participate in the Company’s distribution waterfall in effect prior to the Reorganization).

 Grant Date

 Award Type(2)

 Vesting Type(1)

 Granted

 Fair Value per Share

 Total
 Equity Value (in millions)

 2/21/2024

 Equity

 Time

 2,707

 $
 105.81

 $
 4,100

 2/21/2024

 Equity

 Performance

 3,607

 $
 131.73

 $
 4,100

 2/21/2024

 Phantom

 Time

 267

 $
 105.81

 $
 4,100

 2/21/2024

 Phantom

 Performance

 356

 $
 131.73

 $
 4,100

 5/29/2024

 Equity

 Time

 1,088

 $
 105.81

 $
 4,100

 5/29/2024

 Equity

 Performance

 1,447

 $
 131.73

 $
 4,100

 5/29/2024

 Phantom

 Time

 158

 $
 105.81

 $
 4,100

 5/29/2024

 Phantom

 Performance

 211

 $
 131.73

 $
 4,100

 6/17/2024

 Equity

 Time

 5,178

 $
 192.07

 $
 3,900

 6/17/2024

 Equity

 Performance

 6,903

 $
 226.62

 $
 3,900

 8/14/2024

 Equity

 Time

 1,568

 $
 105.81

 $
 3,900

 8/14/2024

 Equity

 Performance

 2,089

 $
 131.73

 $
 3,900

 8/14/2024

 Phantom

 Time

 201

 $
 105.81

 $
 3,900

 8/14/2024

 Phantom

 Performance

 269

 $
 131.73

 $
 3,900

 11/20/2024

 Equity

 Time

 5,070

 $
 105.81

 $
 3,900

 11/20/2024

 Equity

 Performance

 602

 $
 131.73

 $
 3,900

 11/20/2024

 Phantom

 Time

 7,178

 $
 105.81

 $
 3,900

 11/20/2024

 Phantom

 Performance

 9,571

 $
 131.73

 $
 3,900

 5/21/2025

 Equity

 Time

 3,919

 $
 576.79

 $
 5,200

 5/21/2025

 Equity

 Performance

 5,226

 $
 601.84

 $
 5,200

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 Division of Corporation Finance
 Securities and Exchange Commission July 22, 2025
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