United States securities and exchange commission logo

                            June 24, 2022

       Chinh Chu
       Chief Executive Officer
       Vector Holding, LLC
       251 Little Falls Drive
       Wilmington, New Castle County, Delaware 19808

                                                        Re: Vector Holding, LLC
                                                            Amendment No. 3 to
Registration Statement on Form S-4
                                                            Filed June 13, 2022
                                                            File No. 333-262203

       Dear Mr. Chu:

             We have reviewed your amended registration statement and have the
       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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
18, 2022 letter.

       Amendment No. 3 to Form S-4 filed June 13, 2022

       Certain Engagements in Connection with the Business Combination and
Related Transactions,
       page 158

   1.                                                   We note your disclosure
in the last paragraph on page 158 that "Each of Redburn (USA)
                                                        LLC, Loop Capital
Markets LLC and The Benchmark Company, LLC was engaged by
                                                        CCNB to act as a
capital markets advisor." For each of these advisors, please expand the
                                                        disclosure to include a
description of the role of the financial advisor in the de-SPAC
 Chinh Chu
FirstName  LastNameChinh Chu
Vector Holding, LLC
June       NameVector Holding, LLC
     24, 2022
June 24,
Page 2 2022 Page 2
FirstName LastName

2.       We note the revised legal opinion, Exhibit 5.1, in response to comment
2. Please revise to
         disclose the purpose and scope of your reliance on the Maples and
Calder opinion, and
         give us your analysis of whether you need to file the Maples and
Calder opinion as an
         exhibit to the registration statement, refer to Maples & Calder in
your disclosure and/or
         file a consent of Maples and Calder as an exhibit. Refer to Staff
Legal Bulletin No. 19 for
         further guidance.
       You may contact Tony Watson at 202-551-3318 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Stacey Peikin at 202-551-6223 or Lilyanna Peyser at 202-551-3222 with
any other


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