United States securities and exchange commission logo

                     January 3, 2024

       Jennifer Leyden
       Chief Financial Officer
       Getty Images Holdings, Inc.
       605 5th Ave. S. Suite 400
       Seattle, WA 98104

                                                        Re: Getty Images
Holdings, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            File No. 001-41453

       Dear Jennifer Leyden:

              We have completed our review of your filing. 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.


                     Division of Corporation Finance

                     Office of Trade & Services