September 26, 2024

Glenn Luinenburg
Partner, Wilmer Cutler Pickering Hale & Dorr LLP
ARC Document Solutions, Inc.
2600 El Camino Real
Suite 400
Palo Alto, CA 94306

       Re: ARC Document Solutions, Inc.
           Schedule 13E-3 filed by ARC Document Solutions, Inc. et al.
           Filed September 11, 2024
           File No. 005-81438
           _
           Preliminary Proxy Statement
           Filed September 11, 2024
           File No. 001-32407
Dear Glenn Luinenburg:

       We have reviewed your filings and have the following comments. In some
of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

        Please respond to these comments by providing the requested information
or advise us as
soon as possible when you will respond. If you do not believe our comments
apply to your facts
and circumstances, please tell us why in your response.

       After reviewing your response to these comments, we may have additional
comments.

Preliminary Proxy Statement
General

1.     Please provide the disclosure required under Item 1015 of Regulation M-A
with respect to
       AlixPartners.
Summary Term Sheet, page 1

2.     Please revise the Summary Term Sheet and Q&A sections to shorten them
significantly
       and to avoid duplication. Also, relocate the "Defined Terms" section
currently appearing
       in front of the Special Factors to after it. Refer to Rule 13e-3(e)(1).
 September 26, 2024
Page 2

Purpose and Reasons of ARC for the Merger, page 35

3.     We note that the fairness determination disclosure is made with respect
to the company's
       shareholders "(other than the Rollover Stockholders)" instead of with
respect to
       unaffiliated security holders. In this respect, we note that your
officers and directors are
       affiliates. Please revise here and throughout the filing to more clearly
and consistently
       articulate whether the going private transaction is substantively and
procedurally fair to
       security holders who are not affiliates of ARC Document Solutions. See
Item 1014(a) of
       Regulation M-A.
4.     Note that if any filing person has based its fairness determination on
the analysis of
       factors undertaken by others, such person must expressly adopt this
analysis and
       discussion as their own in order to satisfy the disclosure obligation.
See Question 20 of
       Exchange Act Release No. 34-17719 (April 13, 1981). Please revise to
ensure, if true, that
       the special committee adopted the William Blair analysis and opinion and
that the board
       of directors adopted the special committee's analysis and conclusion.
5.     Please revise this section to describe how the special committee and
board of directors
       reached their fairness determinations based on the William Blair
opinion, given that such
       opinion addressed fairness to a subset of shareholders that included
your officers and
       directors, while the special committee and board of directors are
required to make a
       fairness determination with respect to unaffiliates security holders.
Opinion of the Special Committee's Financial Advisor, page 42

6.     Please revise to disclose the data underlying the results in the
Selected Public
       Companies Analysis and the Selected Precedent Transactions Analysis.
7.     Please provide the disclosure required under Item 1015(b)(4) of
Regulation M-A with
       respect to William Blair.
Purpose and Reasons of the Purchaser Filing Parties for the Merger, page 54

8.     Please remove the language here and throughout your proxy statement
stating that the
       Purchaser Filing Parties "may be deemed to be affiliates of ARC..." as
you have
       determined to file a Schedule 13E-3.
Certain Unaudited Prospective Financial Information, page 59

9.     Please include the full projections instead of their summaries.
Cautionary Statement Concerning Forward-Looking Information, page 101

10.    Please delete reference to the Private Securities Litigation Reform Act
of 1995, as the safe
       harbor provisions of the Act are not available to statements made in
connection with a
       going private transaction.
 September 26, 2024
Page 3

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please direct any questions to Daniel Duchovny at 202-551-3619.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Mergers &
Acquisitions