April 26, 2021

Via EDGAR Transmission

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Scott Anderegg

 

Re:

Endeavor Group Holdings, Inc.

Registration Statement on Form S-1

Filed March 31, 2021

Registration No. 333-254908

Dear Mr. Anderegg

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request the acceleration of the effective date of the above-referenced Registration Statement so that it will become effective on April 28, 2021, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, or at such later time as Endeavor Group Holdings, Inc. (the “Company”) or its counsel may request via telephone call to the staff. Please contact Ian Schuman of Latham & Watkins LLP, counsel to the Company, at (212) 906-1894, or in his absence, Marc Jaffe at (212) 906-1281, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.

 

cc:     Justin G. Hamill, Esq., Latham & Watkins LLP

Marc D. Jaffe, Esq., Latham & Watkins LLP

Ian D. Schuman, Esq., Latham & Watkins LLP

Benjamin J. Cohen, Esq., Latham & Watkins LLP