September 15, 2023
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: Rucha Pandit
| Re: | TKO Group Holdings, Inc. |
| Registration Statement on Form S-1 |
| Filed September 15, 2023 |
| Registration No. 333-274541 |
Dear Rucha Pandit,
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 September 19, 2023, at 4:30 p.m., Eastern Time, or as soon thereafter as practicable, or at such later time as TKO Group Holdings, Inc. (the “Company”) or its counsel may request via telephone call to the staff. Please contact Benjamin Cohen of Latham & Watkins LLP, counsel to the Company, at (212) 906-1623 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.
| Very truly yours, |
| TKO GROUP HOLDINGS, INC. |
| /s/ Andrew Schleimer |
| Name: Andrew Schleimer |
| Title: Chief Financial Officer |
| cc: | Justin G. Hamill, Esq., Latham & Watkins LLP |
Marc D. Jaffe, Esq., Latham & Watkins LLP
Michael V. Anastasio, Esq., Latham & Watkins LLP
Benjamin J. Cohen, Esq., Latham & Watkins LLP