United States securities and exchange commission logo May 1, 2023 Mark Walker Chairman and Chief Executive Officer Direct Digital Holdings, Inc. 1177 West Loop South, Suite 1310 Houston, TX 77207 Re: Direct Digital Holdings, Inc. Registration Statement on Form S-3 Filed April 21, 2023 File No. 333-271382 Dear Mark Walker: 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 Taylor Beech at 202-551-4515 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Rakesh Gopalan, Esq.