United States securities and exchange commission logo December 27, 2021 Brian Cabrera Chief Legal and Compliance Officer Quantum Corporation 224 Airport Parkway, Suite 550 San Jose, CA 95110 Re: Quantum Corporation Registration Statement on Form S-3 Filed December 17, 2021 File No. 333-261733 Dear Mr. Cabrera: 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 Derby, Staff Attorney, at (202) 551-3334 or Joshua Shainess, Legal Branch Chief, at (202) 551-7951 with any questions. Sincerely, Division of Corporation Finance Office of Technology