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CORRESP Filing

SMITHFIELD FOODS INC
Date: Sept. 3, 2025 · CIK: 0000091388 · Accession: 0001213900-25-083713

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File numbers found in text: 333-290000

Date
September 3, 2025
Author
By
Form
CORRESP
Company
SMITHFIELD FOODS INC

Letter

Smithfield Foods, Inc. 200 Commerce Street

Smithfield, VA 23430

September 3, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Erin Donahue

Re: Smithfield Foods, Inc.

Registration Statement on Form S-1 (File No. 333-290000)

Request for Acceleration of Effective Date

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Smithfield Foods, Inc. (the " Company ") hereby respectfully requests that the effectiveness of the Registration Statement on Form S-1 (File No. 333-290000) of the Company, filed with the Securities and Exchange Commission (the " Commission ") on September 3, 2025, as amended (the " Registration Statement "), be accelerated so that such Registration Statement shall become effective at 4:00 p.m., Eastern Time, on September 4, 2025 or as soon as possible thereafter.

It would be appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Colin J. Diamond of Paul Hastings LLP, by telephone at (212) 318-6007 or by email at colindiamond@paulhastings.com and Brandon J. Bortner of Paul Hastings LLP, by telephone at (202) 551-1840 or by email at brandonbortner@paulhastings.com. The Company hereby authorizes Colin J. Diamond or Brandon J. Bortner of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

Sincerely,
SMITHFIELD FOODS, INC.

Show Raw Text
CORRESP
 1
 filename1.htm

 Smithfield Foods, Inc.
200 Commerce Street

 Smithfield, VA 23430

 September 3, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Erin Donahue

 Re: Smithfield Foods, Inc.

 Registration Statement on Form S-1 (File
No. 333-290000)

 Request for Acceleration of Effective
Date

 Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Smithfield Foods, Inc. (the " Company ") hereby respectfully requests
that the effectiveness of the Registration Statement on Form S-1 (File No. 333-290000) of the Company, filed with the Securities
and Exchange Commission (the " Commission ") on September 3, 2025, as amended (the " Registration Statement "),
be accelerated so that such Registration Statement shall become effective at 4:00 p.m., Eastern Time, on September 4, 2025 or as soon
as possible thereafter.

 It would be appreciated if,
promptly after the Registration Statement has become effective, you would so inform our outside counsel, Colin J. Diamond of Paul Hastings
LLP, by telephone at (212) 318-6007 or by email at colindiamond@paulhastings.com and Brandon J. Bortner of Paul Hastings LLP, by telephone
at (202) 551-1840 or by email at brandonbortner@paulhastings.com. The Company hereby authorizes Colin J. Diamond or Brandon J. Bortner
of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

 Sincerely,

 SMITHFIELD FOODS, INC.

 By:
 /s/ C. Shane Smith

 Name:
 C. Shane Smith

 Title:
 Chief Executive Officer

 cc: Colin J. Diamond, Esq. (Paul Hastings LLP)

 Brandon J. Bortner, Esq. (Paul Hastings LLP)