April 20, 2021

 

VIA EDGAR

 

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 

Attention:

Asia Timmons-Pierce

Jay Ingram 

Division of Corporation Finance

Office of Manufacturing

 

Re:

Latham Group, Inc. (f/k/a Latham Topco, Inc.) Registration Statement on Form S-1

File No. 333-254930

 

Acceleration Request

Requested Date: April 22, 2021

Requested Time: 3:00 p.m., Eastern Standard Time

 

Ladies and Gentlemen:

 

In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), Barclays Capital Inc., BofA Securities, Inc., Morgan Stanley & Co. LLC, and Goldman Sachs & Co. LLC, as representatives of the several underwriters, hereby join Latham Group, Inc. in requesting that the Securities and Exchange Commission take appropriate action to cause the Registration Statement on Form S-1 (File No. 333-254930) (the “Registration Statement”) to become effective on April 22, 2021 at 3:00 p.m., Eastern Standard Time, or as soon as practicable thereafter.

 

Pursuant to Rule 460 under the Act, please be advised that we will take reasonable steps to secure adequate distribution of the preliminary prospectus, to underwriters, dealers, institutions and others, prior to the requested effective time of the Registration Statement.

 

We advise that we have complied and will continue to comply, and that we have been informed by the participating underwriters that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, to the extent applicable.

 

[Signature Page Follows]

 

 

	Very truly yours,
	By Barclays Capital Inc.
	By:	/s/ Robert Stowe
		Name: Robert Stowe
		Title:   Managing Director
	By BofA Securities, Inc.
	By:	/s/ Thomas Bradshaw
		Name: Thomas Bradshaw
		Title: Managing Director
	By Morgan Stanley & Co. LLC
	By:	/s/ Jacqueline Murphy
		Name: Jacqueline Murphy
		Title: Vice President
	By Goldman Sachs & Co. LLC
	By:	/s/ Terry Hagerty
		Name: Terry Hagerty
		Title: Managing Director

 

[Signature Page to Underwriter Acceleration Request]