United States securities and exchange commission logo June 22, 2020 Glenn H. Schiffman Executive Vice President and Chief Financial Officer IAC Holdings, Inc. 555 West 18th Street New York, New York 10011 Re: IAC Holdings, Inc. Registration Statement on Form S-1 Filed June 16, 2020 File No. 333-239204 Dear Mr. Schiffman: 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 Katherine Bagley at (202) 551-2545 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jenna E. Levine