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SEC Company Response from Distribution Solutions Group, Inc. (DSGR) (CIK 0000703604) (DSGR) — May 30, 2019

Distribution Solutions Group, Inc. (DSGR) (CIK 0000703604)
Date: May 30, 2019 · CIK: 0000703604 · Accession: 0001193125-19-160649

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File numbers found in text: 333-231671

Date
May 30, 2019
Author
/s/ Neil E. Jenkins
Form
CORRESP
Company
Distribution Solutions Group, Inc. (DSGR) (CIK 0000703604)

Letter

Lawson Products, Inc.

8770 West Bryn Mawr Avenue, Suite 900

Chicago, IL 60631

May 30, 2019

VIA EDGAR SUBMISSION

Securities and Exchange Commission

Division of Corporation Finance

Office of Manufacturing and Construction

100 F Street, N.E.

Washington, D.C. 20549

Attn: Edward M. Kelly, Senior Counsel

Re: Lawson Products, Inc.

Registration Statement on Form S-3

File No. 333-231671

Request for Effectiveness

Ladies and Gentlemen:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, Lawson Products, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-3, File No. 333-231671 (the “Registration Statement”) so that it may become effective at 12:00 noon Eastern Time on Monday, June 3, 2019 or as soon thereafter as practicable.

The Company hereby acknowledges that:

(a) should the United States Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(b) the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; and

(c) it may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

* * *

Mr. Edward M. Kelly

May 30, 2019

Page 2

We respectfully request that you notify Tom Monson of Jenner & Block LLP at 312-840-8611 when the Registration Statement is declared effective.

Sincerely,
/s/ Neil E. Jenkins

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CORRESP
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CORRESP

 Lawson Products, Inc.

8770 West Bryn Mawr Avenue, Suite 900

Chicago, IL 60631

 May 30, 2019

VIA EDGAR SUBMISSION

 Securities and
Exchange Commission

 Division of Corporation Finance

 Office
of Manufacturing and Construction

 100 F Street, N.E.

Washington, D.C. 20549

 Attn: Edward M. Kelly, Senior Counsel

Re:
 Lawson Products, Inc.

 Registration Statement on Form S-3

 File No. 333-231671

 Request for Effectiveness

Ladies and Gentlemen:

 Pursuant to Rule 461 of
the Securities Act of 1933, as amended, Lawson Products, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-3, File No. 333-231671 (the “Registration Statement”) so that it may become effective at 12:00 noon Eastern Time on Monday, June 3, 2019 or as soon thereafter as practicable.

The Company hereby acknowledges that:

(a) should the United States Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated
authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

(b) the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does
not relieve the Company from its full responsibility for the accuracy and adequacy of the disclosure in the Registration Statement; and

(c) it may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

 *    *    *

 Mr. Edward M. Kelly

May 30, 2019

 Page 2

 We respectfully request that you notify Tom Monson of Jenner &
Block LLP at 312-840-8611 when the Registration Statement is declared effective.

Sincerely,

 /s/ Neil E. Jenkins

Neil E. Jenkins

 Executive Vice President, Secretary and General
Counsel

 Lawson Products, Inc.

cc:
 Thomas A. Monson, Jenner & Block LLP