August 12, 2025

Jeffrey Likosar
President and Chief Financial Officer
ADT Inc.
1501 Yamato Road
Boca Raton, FL 33431

        Re: ADT Inc.
            Form 10-K for Fiscal Year Ended December 31, 2024
            File No. 001-38352
Dear Jeffrey Likosar:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       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 10-K for Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Revenue
Security installation, product, and other, page 57

1.     You disclose on page 52 that "beginning in the second quarter of 2024, a
growing
       number of our direct channel new customer adds are outright sales in
connection with
       the national launch of our new ADT+ platform" and attribute the majority
of the
       growth in your 'Security, product, and other revenue' to the transition
to the ADT+
       platform. Please enhance your disclosure to describe any known trends
that have had
       or that are reasonably likely to have a material favorable or
unfavorable impact on net
       sales or revenues or income from continuing operations. For example,
your ADT+
       platform is compatible with Google Nest products which appears to have
driven more
       products sales and installations under the customer-owned equipment
model. Refer to
       Item 303(b)(2)(ii) of Regulation S-K.
 August 12, 2025
Page 2

        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 Robert Shapiro at 202-551-3273 or Lyn Shenk at
202-551-3380 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services