January 30, 2026

J. Lindsey Alley
Chief Financial Officer
Houlihan Lokey, Inc.
10250 Constellation Blvd.
5th Floor
Los Angeles, California 90067

        Re: Houlihan Lokey, Inc.
            Form 10-K for the Fiscal Year Ended March 31, 2025
            Form 8-K filed January 29, 2026
            File No. 001-37537
Dear J. Lindsey Alley:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 8-K filed January 29, 2026
Exhibit 99.1
Non-GAAP Financial Measures, page 5

1.     Please revise your disclosures in future filings to further discuss the
reasons why you
       believe that presentation of these non-GAAP financial measures provide
useful
       information to investors and describe each of the adjusting items. Refer
to paragraph
       (e)(1)(i)(C) of Item 10 of Regulation S-K.
Reconciliation of GAAP to Adjusted Financial Information, page 8

2.     We note the adjustments for "acquisition related compensation and
benefits" in each of
       your non-GAAP measures appear to include deferred retention payments
related to
       certain acquisitions. Please tell us and quantify the components
comprising each of
       this adjustment for each period presented and clarify whether these
payments are settled
       in cash and require continued employment. As part of your response,
please explain how
       you determined that these were not normal, recurring, cash operating
expenses of your
 January 30, 2026
Page 2

       business. Refer to Question 100.01 of the non-GAAP C&DIs.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Michael Henderson at 323-965-3807 or Robert Klein at
202-551-3847
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Finance