The 165Ho(n, γ) cross section was measured at the Oak Ridge Electron Linear Accelerator neutron time-of-flight facility. Nonhydrogenous scintillation detectors were used with pulse-height weighting to measure the prompt photon yield, normalized to the saturated 3.92-eV resonance in (165Ho + n) and the shape of the 6Li(n, α) cross section. Resonance parameters for many of the observed peaks below 3 keV were determined by a nonlinear least-squares fit. The data to 100 keV were well fitted with energy-independent strength functions 104 S0 = 1.33 ± 0.14, 104 S1 = 1.36 ± 0.24, 104S2 = 1.19 ± 0.76 and γ/D0 = 0.076/(3.23 ± 0.55 eV). The fluctuations of the cross section about the strength function fit are analyzed for 250-eV averages. The Wald-Wolfowitz “Runs” test is consistent with no additional nonrandom structure in the cross section.