July 7, 2025

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

       Re: Kyndryl Holdings, Inc.
           Form 10-K for the Fiscal Year Ended March 31, 2025
           File No. 001-40853
Dear David Wyshner:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended March 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Segment Results
Costs and Expenses, page 35

1.     We note you refer to several factors impacting period-over-period change
in your
       operating expenses. For example, you state the decrease in cost of
services was due to
       lower depreciation expense, increased operating efficiencies, higher
margins on recent
       signings and a vendor credit. Where a material change is attributed to
two or more
       factors, including any offsetting factors, please revise to describe the
contribution of
       each factor in quantified terms. Refer to Item 303(b) of Regulation S-K.
Other Information, page 40

2.     We note that management uses signings as a tool to monitor the
performance of the
       business including your ability to attract new customers and sell
additional scope into
       your existing customer base. We further note from your risk factor
disclosure on page
       14 that your revenues may be impacted by your ability to attract new
customers, retain
 July 7, 2025
Page 2

       existing customers and sell additional services with greater gross
margins. Please tell
       us your consideration to provide a quantified discussion of the impact
of new versus
       existing customers on your signings. We refer you to the revised
disclosures provided
       in response to comment 5 of our September 17, 2021 letter.
Alternatively, tell us what
       measures management uses to monitor your ability to attract new
customers and retain
       existing customers, and revise to include a quantified discussion of
such measures for
       each period presented. Refer to SEC Release No. 33-10751.
3.     We note the company has taken actions to reduce unprofitable and
low-margin
       components of your customer relationships. We also note the references
in your
       earnings call and investor presentation to pre-spin low margin signings
compared to
       post-spin higher margin signings. Please tell us your consideration to
include
       a quantified discussion of the impact of pre- and post-spin signings on
each of your
       segment's revenue and results of operations.
4.     We note you present and discuss gross profit book-to-bill in your
earnings call for the
       quarter ended March 31, 2025 and in the related Fourth Quarter 2025
Earnings
       Presentation. In addition, you state in the investor presentation that
management uses
       book-to-bill and gross profit book-to-bill as tools to monitor the
performance of the
       business including the business' ability to attract new customers and
sell additional
       scope into your existing customer base. Please tell us how projected
gross profit on
       signings for the trailing twelve months, which is used in your
calculation of projected
       gross profit book-to-bill, is calculated. Also, clarify whether the
actual gross profit
       used in such calculation agrees to revenue less cost of services as
provided in your
       income statement or explain how such amount is determined. In addition,
tell us
       whether these are key performance measures used in managing your
business and if
       so, how you considered including a quantified discussion of these
metrics for each
       period presented in your periodic filings.
        In closing, 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 Megan Masterson at 202-551-3407 or Kathleen Collins at
202-551-
3499 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   Edward Sebold