Room 4561
March 15, 2006

Mr. Richard E. Belluzo
Chief Executive Officer
Quantum Corporation
1650 Technology Drive
Suite 800
San Jose, California 95110

      Re:	Quantum Corporation
      Form 10-K for the Fiscal Year Ended March 31, 2005
		Filed June 8, 2005
		Form 8-K
		Filed October 27, 2005
		File No. 1-13449

Dear Mr. Belluzo,

      We have reviewed your response letter dated February 28,
2006
and have the following comments.  Where indicated, we think you
should revise your document in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  After reviewing this information,
we
may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.










Form 10-K for the Fiscal Year Ended March 31, 2005

GAAP to Non-GAAP Reconciliation of Consolidated Statements of
Operations, pages 79 through 82

1. We have read your response to prior comment number 3 and note
that
you define "special charges" as non-recurring, infrequent and
unusual
items.  Please explain to us how your presentation, included
within
this document that was filed with the Commission, complies with
Item
10(e)(1)(ii)(B).  In this regard, it is unclear to us why you
believe
it was appropriate to exclude these restructuring charges from
your
GAAP results considering that similar charges appear to have been
incurred within the two-year period contemplated by Item
10(e)(1)(ii)(B).

2. In view of the nature, content and format of your presentation,
we
question whether it complies with Item 100(b) of Regulation G.  In
this regard we note that presentation of a full non-GAAP Statement
of
Operations may create the unwarranted impression that the
presentation is based on a comprehensive set of accounting rules
or
principles.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

      You may contact Mark Kronforst, Senior Staff Accountant at
(202) 551-3451 or me at (202) 551-3489 if you have any questions
regarding these comments.

							Sincerely,


							Brad Skinner
						Accounting Branch Chief
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Richard E. Belluzo
Quantum Corporation
March 15, 2006
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