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                             August 28, 2023

       Spencer Collins
       Chief Legal Officer
       Arm Holdings Limited
       110 Fulbourn Road
       Cambridge CB1 9NJ
       United Kingdom

                                                        Re: Arm Holdings
Limited
                                                            Registration
Statement on Form F-1
                                                            Filed August 21,
2023
                                                            File No. 333-274120

       Dear Spencer Collins:

             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.

       Form F-1 filed August 21, 2023

       Capitalization, page 84

   1.                                                   We note that the table
presents your cash and cash equivalents and capitalization as of
                                                        June 30, 2023. Please
remove the cash and cash equivalents from your total capitalization
                                                        amounts, as cash and
cash equivalents are not part of your capitalization, and include bold
                                                        or double underlines
and additional spacing following the cash and cash
                                                        equivalents amounts to
highlight to investors that the two amounts are separate.
 Spencer Collins
FirstName LastNameSpencer  Collins
Arm Holdings  Limited
Comapany
August 28, NameArm
           2023      Holdings Limited
August
Page 2 28, 2023 Page 2
FirstName LastName
       You may contact Heather Clark at 202-551-3624 or Martin James at
202-551-3671 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at 202-551-3454 with
any other
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Manufacturing
cc:      Justin Salon