January 13, 2025 Brad S. Lakhia Executive Vice President and Chief Financial Officer OPENLANE, Inc. 11299 N. Illinois Street, Suite 500 Carmel, Indiana 46032 Re: OPENLANE, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-34568 Dear Brad S. Lakhia: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Charles S. Coleman