0001104659-21-125724.txt : 20211112 0001104659-21-125724.hdr.sgml : 20211112 20211013104946 ACCESSION NUMBER: 0001104659-21-125724 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20211013 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Kyndryl Holdings, Inc. CENTRAL INDEX KEY: 0001867072 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-COMPUTER PROCESSING & DATA PREPARATION [7374] IRS NUMBER: 861185492 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE VANDERBILT AVENUE STREET 2: 15TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10017 BUSINESS PHONE: (212) 896-2098 MAIL ADDRESS: STREET 1: ONE VANDERBILT AVENUE STREET 2: 15TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10017 FORMER COMPANY: FORMER CONFORMED NAME: Kyndryl Holdings, LLC DATE OF NAME CHANGE: 20210611 CORRESP 1 filename1.htm

KYNDRYL HOLDINGS, INC.
One Vanderbilt Avenue, 15th Floor
New York, NY 10017

October 13, 2021

VIA EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549

Attention:

Jan Woo and Matthew Derby

Re:

Kyndryl Holdings, Inc.
Form 10-12B
File No. 001-40853

Dear Ms. Woo and Mr. Derby:

In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended, Kyndryl Holdings, Inc. hereby respectfully requests that the effective date of its Registration Statement on Form 10 (File No. 001-40853) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission to 3:00 p.m., New York City time, on October 14, 2021, or as soon thereafter as practicable.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform John C. Kennedy at (212) 373-3025, with written confirmation sent to the address listed on the cover of the Registration Statement to follow.

	Sincerely,

	KYNDRYL HOLDINGS, INC.

	By:	/s/ Simon J. Beaumont
		Name: Simon J. Beaumont
		Title: President