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                            August 6, 2021

       Nicholas P. Robinson
       Chief Executive Officer
       King Pubco, Inc.
       875 Third Avenue
       New York, NY 10022

                                                        Re: King Pubco, Inc.
                                                            Amendment No. 3 to
Registration Statement on Form S-4
                                                            Filed July 28, 2021
                                                            File No. 333-255121

       Dear Mr. Robinson:

              We have reviewed your amended registration statement and have the
following
       comment. Our comment may ask you to provide us with information so we
may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this comment, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our July
22, 2021 letter.

       Amendment No. 2 to Form S-4

       Key Metrics, page 241

   1.                                                   We note your disclosure
of Total Revenue Churn added in response to prior comment 1.
                                                        Please address the
following:
                                                            You disclose on
page 166 that historically, it has taken several years when non-core
                                                            customers churn off
your platform. Tell us whether the same pattern is true for your
                                                            other customers
and, in light of this, tell us why you present churn for only a
                                                            three month period
for customers who reduce their revenue to zero.
                                                            Revise to disclose
how management uses this metric and why it is useful to investors.
                                                            Revise to disclose
this metric for your annual periods in addition to the quarterly
                                                            periods already
disclosed.
 Nicholas P. Robinson
King Pubco, Inc.
August 6, 2021
Page 2
             Clarify how the annual periods are calculated and to the extent
such calculations are
           based off of revenues declining to zero in a particular quarter,
explain further how
           that is representative of annual churn.
             Tell us how churn, as defined on page 242, relates to the $1.9
million and $11.2
           million of churning customers from old tranches for the three months
ended March
           31, 2021 and the year ended, December 31, 2020, respectively, as
disclosed in your
           results of operations discussion. In this regard, to the extent
these amounts represent
           the loss of revenue from go-forward customers that have communicated
their intent
           not to provide future business to Kore, explain further why or how
this differs from
           your definition of churn.

       You may contact Rebekah Lindsey, Senior Staff Accountant, at (202)
551-3303 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have
questions regarding
comments on the financial statements and related matters. Please contact Edwin
Kim, Staff
Attorney, at (202) 551-3297 or Kathleen Krebs, Special Counsel, at (202)
551-3350 with any
other questions.



                                                             Sincerely,
FirstName LastNameNicholas P. Robinson
                                                             Division of
Corporation Finance
Comapany NameKing Pubco, Inc.
                                                             Office of
Technology
August 6, 2021 Page 2
cc:       Neil Whoriskey, Esq.
FirstName LastName