October 9, 2024

Paul Bay
Chief Executive Officer
Ingram Micro Holding Corporation
3351 Michelson Drive, Suite 100
Irvine, CA 92612

       Re: Ingram Micro Holding Corporation
           Registration Statement on Form S-1
           Filed September 30, 2024
           File No. 333-282404
Dear Paul Bay:

       We have reviewed your registration statement and have the following
comment(s).

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1
Summary
Recent Developments
Preliminary Estimated Operating Results for the Thirteen Weeks Ended September
28, 2024,
page 12

1.     Please remove your statement that readers should not place undue
reliance on your
       preliminary estimates, as investors should be able to rely on the
information
       presented. Please also clearly state, if true, that the basic and
diluted earnings per
       share information gives effect to the stock split discussed on page 22.
 October 9, 2024
Page 2
The Offering, page 19

2.     Page 22 indicates that a stock split will occur in conjunction with this
offering. If it
       occurs prior to the effectiveness of this registration statement, please
also revise your
       financial statements to give retroactive effect to the stock split.
Otherwise, disclose, if
       true, that the stock split will occur after the effectiveness of this
registration statement,
       but prior to the consummation of this offering. Refer to ASC
260-10-55-12 and SAB
       Topic 4:C.
Risk Factors
Risks Related to Our Reliance on Third Parties
We face a variety of risks in our reliance on third-party service companies...,
page 57

3.     We note your amended disclosure in response to prior comment 1. Please
expand your
       disclosure to identify the major, large-scale cloud service provider
that hosts Ingram
       Micro Xvantage. To provide additional context to investors, please also
explain the
       applicable licensing terms or arrangements with such provider.

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Keira Nakada at 202-551-3659 or Rufus Decker at
202-551-3769 if
you have questions regarding comments on the financial statements and related
matters. Please contact Alyssa Wall at 202-551-8106 or Mara Ransom at
202-551-3264 with
any other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services
cc:   Cristopher Greer