QUANTUM CORP /DE/ — Regulatory Filings 2025

Apr 24, 2025

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QUANTUM CORPORATION

224 Airport Parkway, Suite 550

San Jose, CA 95110

April 24, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Edwin Kim

Re:
File No. 333-286635

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Quantum Corporation (the “Registrant”) hereby requests that the above-referenced registration statement on Form S-3 (File No. 333-286635) (the “Registration Statement”) be declared effective on April 28, 2025, at 4:30 p.m., Eastern Time, or as soon thereafter as is practicable, or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes each of Julie Park and James J. Masetti of Pillsbury Winthrop Shaw Pittman LLP, counsel to the Registrant, to make such request on its behalf. The Registrant hereby also authorizes each of Julie Park and James J. Masetti of Pillsbury Winthrop Shaw Pittman LLP to orally modify or withdraw this request for acceleration.

Once the Registration Statement has been declared effective, please orally confirm that event with Julie Park at (650) 233-4067, or in her absence, James J. Masetti of Pillsbury Winthrop Shaw Pittman LLP at (650) 233-4754.

[ Signature Page Follows ]

Sincerely,
QUANTUM CORPORATION
By:	/s/ Brian E. Cabrera
	Brian E. Cabrera
	Senior Vice President, Chief Administrative Officer, Chief Legal and Compliance Officer, and Corporate Secretary

cc:
Julie Park