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                              December 17, 2020

       Ezra Rosensaft
       Chief Executive Officer
       IDW Media Holdings, Inc.
       520 Broad St.
       Newark, NJ 07102

                                                        Re: IDW Media Holdings,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed December 9,
2020
                                                            File No. 333-249511

       Dear Mr. Rosensaft:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we 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 comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 13, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed December 9,
2020

       Cover Page

   1.                                                   We note that you have
calculated the registration fee under Rule 457(o). Because you are
                                                        registering a specific
number of shares, and not a dollar amount, it appears that you should
                                                        calculate the
registration fee under Rule 457(a). Please advise and revise as appropriate.
                                                        Please also confirm
that although the fixed price of $3.73 is based on the closing price
                                                        from specific days in
December, selling stockholders will sell at this price for the duration
                                                        of the offering, or
until your stock is listed on an established trading market.
 Ezra Rosensaft
FirstName
IDW MediaLastNameEzra
           Holdings, Inc.Rosensaft
Comapany17,
December  NameIDW
              2020 Media Holdings, Inc.
December
Page 2    17, 2020 Page 2
FirstName LastName
General

2.       We note that footnotes 5 and 8 in the Summary Compensation Table
relate to bonus
         payments, not salary. Please revise. We also note that the footnote to
the Beneficial
         Ownership Table references Class A Common Stock, not Class C Common
Stock. Please
         revise.
        You may contact Theresa Brillant at (202) 551-3307 or Rufus Decker at
(202) 551-3769
if you have questions regarding comments on the financial statements and
related
matters. Please contact Cara Wirth at (202) 551-7127 or Erin Jaskot at (202)
551-3442 with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:      Dov Schwell, Esq.