GETTY IMAGES HOLDINGS, INC.
605 5th Ave S. Suite 400
Seattle, WA 98104
April 28, 2025
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Eddie Kim |
Division of Corporation Finance
| RE: | Getty Images Holdings, Inc. (the “Company”) |
Registration Statement on Form S-4
File No. 333-286241
Request for Effectiveness
Ladies and Gentlemen:
Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, the Company hereby respectfully requests that the effective date of the Company’s Registration Statement on Form S-4 (File No. 333-286241) filed with the U.S. Securities and Exchange Commission (the “Commission”) on March 31, 2025, as amended on April 28, 2025, be accelerated by the Commission to 4:00 p.m., Eastern Time, on April 30, 2025, or as soon as practicable thereafter.
We request that we be notified of such effectiveness by a telephone call to Todd Freed of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-3714 and that such effectiveness also be confirmed in writing.
| Very truly yours, | ||
| Getty Images Holdings, Inc. | ||
| By: | /s/ Craig Peters | |
| Name: | Craig Peters | |
| Title: | Chief Executive Officer and Director | |
| cc: | Todd E. Freed |
| Skadden, Arps, Slate, Meagher & Flom LLP | |
| cc: | Jon A. Hlafter |
| Skadden, Arps, Slate, Meagher & Flom LLP |