United States securities and exchange commission logo January 31, 2024 Mark Walker Chief Executive Officer Direct Digital Holdings, Inc. 1177 West Loop South ,Suite 1310 Houston, Texas 77027 Re: Direct Digital Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed April 17, 2023 File No. 001-41261 Dear Mark Walker: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Diana Diaz