November 7, 2024

Kenneth Gianella
Chief Financial Officer
Quantum Corporation
224 Airport Parkway, Suite 550
San Jose, CA 95110

       Re: Quantum Corporation
           Form 10-K for Fiscal Year Ended March 31, 2024
           Response dated October 3, 2024
           File No. 001-13449
Dear Kenneth Gianella:

       We have reviewed your October 3, 2024 response to our comment letter and
have the
following comment.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe the
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
September 17, 2024 letter.

Form 10-K for Fiscal Year Ended March 31, 2024
Explanatory Note

1.     You state in your response to prior comment 1 that you did not perform
any recovery
       analysis as a result of the restatement of your previously issued
financial statements.
       You further indicate that because the company paid no cash bonuses for
the restated
       periods and issued no equity related to the financial metrics that were
impacted by the
       restatement, there was no compensation to potentially recover; and
therefore, you
       determined that the company   s clawback policy and Item 402(w)(2) were
not
       applicable. However, it appears that your clawback policy was triggered,
because you
       were required to prepare an accounting restatement to correct an error
in previously
       issued financial statements that was material to your previously issued
financial
       statements. Also, Item 402(w)(2) of Regulation S-K requires disclosure
of a brief
       explanation of why application of your recovery policy resulted in no
recovery of
 November 7, 2024
Page 2

       erroneously awarded compensation when you conclude that recovery is not
required
       pursuant to your recovery policy. Please provide this disclosure in your
next Form
       10-K filing.
        Please contact Joyce Sweeney at 202-551-3449 or Kathleen Collins at
202-551-3499
if you have questions regarding comments on the financial statements and
related matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:   Brian Cabrera