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                             October 9, 2020

       Charlotte MacVane
       General Counsel
       ATI Intermediate Holdings, LLC
       3901 Midway Place NE
       Albuquerque, New Mexico 87109

                                                        Re: ATI Intermediate
Holdings, LLC
                                                            Amendment No. 3 to
                                                            Registration
Statement on Form S-1
                                                            Filed October 8,
2020
                                                            File No. 333-248969

       Dear Ms. MacVane:

             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.

       Registration Statement on Form S-1

       Capitalization, page 50

   1.                                                   To enhance an
investor's understanding, revise the table to include double lines under the
                                                        amounts relating to the
Cash and restricted cash and the Total capitalization captions.
                                                        Please move the
long-term liabilities total amounts (e.g., $30,552, $605,427) to a
                                                        total caption that
follows, rather than precedes, the individual components of long-term
                                                        liabilities.
       Dilution, page 52

   2.                                                   Please refer to Item
506 of Regulation S-K and revise the information provided in (ii) of
                                                        the second paragraph to
address the 7,000,000 common shares being issued and offered
 Charlotte MacVane
ATI Intermediate Holdings, LLC
October 9, 2020
Page 2
      for sale at $20.00 per share by company, rather than the shares offered
by the selling
      stockholder. Further, revise the second table to separately present the
shares, percentages,
      and consideration paid by (i) existing stockholders, (ii) the selling
stockholders, and (iii)
      IPO new investors.
       You may contact Beverly Singleton at 202-551-3328 or Martin James at
202-551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Erin Purnell at 202-551-3454 or Geoffrey Kruczek at 202-551-3641 with
any other
questions.



                                                            Sincerely,
FirstName LastNameCharlotte MacVane
                                                            Division of
Corporation Finance
Comapany NameATI Intermediate Holdings, LLC
                                                            Office of
Manufacturing
October 9, 2020 Page 2
cc:       Michael Kim
FirstName LastName