September 26, 2025

Jennifer Leyden
Senior Vice President and Chief Financial Officer
Getty Images Holdings, Inc.
605 5th Ave. South
Suite 400
Seattle, WA 98104

       Re: Getty Images Holdings, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2024
           Form 10-Q for Fiscal Quarter Ended June 30, 2025
           File No. 001-41453
Dear Jennifer Leyden:

       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 the Fiscal Year Ended December 31, 2024
Note 13. Commitments and Contingencies
Contigencies, page F-26

1.     With regard to the Initial and Follow-On Warrant Litigation, you
disclose on page F-
       29 you have made certain litigation reserves in the Consolidated
Statements of
       Operations. You also disclose you do not currently believe that a
material loss arising
       from the final disposition of existing matters is probable. Please
reconcile these
       disclosures for us.
 September 26, 2025
Page 2
Form 10-Q for Fiscal Quarter Ended June 30, 2025
Condensed Consolidated Statements of Cash Flows , page 5

2.     Please disclose the amounts for interest and income taxes paid for the
six months
       ended June 30, 2025 and 2024. Refer to ASC 230-10-50-2 and 2A.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Foreign exchange loss (gain) - net, page 30

3.     Please enhance your disclosure to explain how the use of
Euro-denominated term debt
       and your exposure to foreign exchange fluctuations due to the generation
of a
       significant portion of your revenues from foreign countries has impacted
your results
       of operations and financial condition for the three and six months ended
June 30,
       2025. Refer to Items 303(a) and (c) of Regulation S-K.
Liquidity and Capital Resources,
Operating Activities, page 35

4.     Please provide a more informative analysis and discussion of changes in
cash flows,
       including changes in working capital components, for each period
presented. In doing
       so, explain the underlying reasons and implications of material changes
between
       periods to provide investors with an understanding of trends and
variability in cash
       flows from operating activities. Ensure your discussion and analysis is
not merely a
       recitation of changes evident from the financial statements. Refer to
Item 303(a) of
       Regulation S-K and sections IV.B and IV.B.1 of SEC Release No. 33-8350.

        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