March 10, 2020

Henry Schuck
Chief Executive Officer
ZoomInfo Technologies Inc.
805 Broadway Street, Suite 900
Vancouver, WA 98660

       Re: ZoomInfo Technologies Inc.
           Registration Statement on Form S-1
           Filed February 27, 2020
           File No. 333-236674

Dear Mr. Schuck:

       We have reviewed your registration statement and have the following
comment. In our
comment, we may ask you to provide us with information so we may better
understand your

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comment applies to your facts
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       After reviewing any amendment to your registration statement and the
information you
provide in response to our comment, we may have additional comments.

Form S-1 filed on February 27, 2020

Impact of the Reorganization Transactions, page 103

1.     We note your response to comment 3 of our letter dated January 27, 2020,
regarding the
       accounting for Zoominfo Opco. We further note that Zoominfo Opco is an
LLC with a
       sole managing member. Please tell us whether Zoominfo Opco will be
accounted for as a
       variable interest entity. If so, please additionally explain to us your
consideration of ASC
       805-10-25-5, which stipulates that when a variable interest entity is
acquired in a business
       combination, the primary beneficiary of that entity is always the
acquirer. Last, tell us
       how you considered the fact that the Reorganization Transactions only
occur when
       contemporaneous with the IPO in determining that the ZoomInfo OpCo
unitholders will
       have nearly identical ownership percentages and economic exposures
before and after
       such transactions.
 Henry Schuck
ZoomInfo Technologies Inc.
March 10, 2020
Page 2

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

       You may contact Becky Chow, Staff Accountant, at (202) 551-6524 or
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
comments on the financial statements and related matters. Please contact Edwin
Kim, Attorney-
Advisor, at (202) 551-3297 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other

FirstName LastNameHenry Schuck
                                                           Division of
Corporation Finance
Comapany NameZoomInfo Technologies Inc.
                                                           Office of Technology
March 10, 2020 Page 2
cc:       Richard Fenyes, Esq.
FirstName LastName