October 1, 2024

Michael Cotoia
Chief Executive Officer
Toro CombineCo, Inc.
275 Grove Street
Newton, Massachusetts 02466

       Re: Toro CombineCo, Inc.
           Amendment No. 2 to Registration Statement on Form S-4
           Filed September 26, 2024
           File No. 333-280529
Dear Michael Cotoia:

     We have reviewed your amended registration statement and have the
following
comments.

       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.

Amendment No. 2 to Registration Statement on Form S-4
Risk Factors
NewCo does not expect to employ its Chief Executive Officer ..., page 83

1.     We note that Gary Nugent, who is expected to serve as NewCo's Chief
Executive Officer
       following the closing of the Transactions, is expected to remain
employed by an affiliate
       of Informa and will provide services to NewCo under a secondment
agreement. Please
       revise to:
           highlight this arrangement earlier in your registration statement,
such as on your
           cover page and summary;
           clarify the affiliate of Informa with which Mr. Nugent will enter
into an employment
           agreement with. In this regard, on page 337 you state that Mr.
Nugent will enter into
           an employment agreement with ISSI and later state he will serve as
the CEO of the
           Informa Tech Digital Business;
           provide an easily understandable definition and explanation of
"secondment
 October 1, 2024
Page 2

            agreement";
              provide a comprehensive discussion of any actual or perceived
conflicts of
            interest that may arise from this arrangement, including a
discussion of any
            competing fiduciary duties Mr. Nugent may have, and discuss how
these conflicts
            will be resolved;
              disclose how many hours per week Mr. Nugent is expected to work
for each of the
            affiliate of Informa and NewCo; and
              enhance your risk factor discussion to discuss risks resulting
from this arrangement.
Signatures, page II-6

2.     We note that Michael Cotoia has signed the registration statement in his
individual
       capacity as a director. Please note that the registration statement must
be signed by your
       principal executive officer. If Mr. Cotoia also signed the registration
statement in his
       capacity as the company's principal executive officer, please revise to
indicate this and
       any other capacity in which he has signed the registration statement.
See Instructions 1
       and 2 to Signatures of Form S-4.
       Please contact Chen Chen at 202-551-7351 or Kathleen Collins at
202-551-3499 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-551-3574
with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:   Andrew Alin