September 6, 2024

Leah Talactac
Chief Financial Officer
Viking Holdings Ltd
94 Pitts Bay Road
Pembroke, Bermuda HM 08

        Re: Viking Holdings Ltd
            Draft Registration Statement on Form F-1
            Filed August 30, 2024
            CIK No. 0001745201
Dear Leah Talactac:

       This is to advise you that we do not intend to review your registration 
statement.

        We request that you publicly file your registration statement no later 
than 48 hours prior to
the requested effective date and time. Please refer to Rules 460 and 461 
regarding requests for
acceleration. 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.

       Please contact Timothy S. Levenberg at 202-551-3707 with any questions.



                                                             Sincerely,

                                                             Division of 
Corporation Finance
                                                             Office of Energy & 
Transportation
cc:   Jonathon Jackson, Esq., of Milbank LLP