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                 August 17, 2022

       David Wyshner
       Chief Financial Officer
       Kyndryl Holdings, Inc.
       One Vanderbilt Avenue, 15th Floor
       New York, New York 10017

                                                        Re: Kyndryl Holdings,
Inc.
                                                            Registration
Statement on Form S-4
                                                            Filed August 9,
2022
                                                            File No. 333-266706

       Dear Mr. Wyshner:

              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 Patrick Faller, Staff Attorney, at (202) 551-4438
or Jan Woo, Legal
       Branch Chief, at (202) 551-3453 with any questions.




                 Sincerely,


                 Division of Corporation Finance

                 Office of Technology
       cc:                                              Evan Barth