United States securities and exchange commission logo December 3, 2020 James J. Lerner President and Chief Executive Officer Quantum Corporation 224 Airport Parkway, Suite 550 San Jose, CA 95110 Re: Quantum Corporation Registration Statement on Form S-3 Filed November 25, 2020 File No. 333-250976 Dear Mr. Lerner: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Matthew Crispino, Staff Attorney, at (202) 551-3456 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Davina Kaile