January 8, 2025 David Johnson Chief Financial Officer Drilling Tools International Corporation 3701 Briarpark Drive Suite 150 Houston, Texas 77042 Re: Drilling Tools International Corporation Registration Statement on Form S-3 Filed January 2, 2025 File No. 333-284109 Dear David Johnson: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Claudia Rios at 202-551-8770 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Ben Smolij, Esq.