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 March 4, 2026

Sophia Hudson
Partner
Kirkland & Ellis LLP
601 Lexington Avenue
New York, NY 10022

 Re: Lands' End, Inc.
 Schedule TO-T filed by LEWHP, LLC
 Filed February 26, 2026
 File No. 005-38004
Dear Sophia Hudson:

 We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

 Please respond to these comments by providing the requested information
or advise us as
soon as possible when you will respond. If you do not believe our comments
apply to your facts
and circumstances, please tell us why in your response.

 After reviewing your response to these comments, we may have additional
comments.

Schedule TO-T
General

1. Please provide us with your detailed legal analysis explaining why you
do not believe
 WH Topco, L.P., as parent of LEWHP, LLC, is a bidder in the offer. For
guidance, refer
 to Rule 14d-1(g)(2), which defines the term bidder as any
person who makes a tender
 offer or on whose behalf a tender offer is made, and Section II.D.2
of the Division of
 Corporation Finance s Current Issues and Rulemaking Projects
Outline (November 14,
 2000; available on our web site at www.sec.gov).
Offer to Purchase -- Summary Term Sheet, page 1

2. We note your disclosure on page 3 as to why you do not believe the
financial condition
 of the bidder to be material to the decision of security holders to
tender their securities in
 the offer. We note that you are outside the purview of Instruction 2 to
Item 10 of
 Schedule TO, which articulates when financial statement are not
material, because this is
 a partial offer by non-reporting bidders. In addition, the offer is for
approximately 7% of
 March 4, 2026
Page 2

 LE's outstanding common shares, with the possibility of acquiring an
additional 2%.
 Under these circumstances, we believe that bidders financial
statements and pro formas
 are material. Please include the disclosure required by Item 10 of
Schedule TO and Item
 1010(a) and (b) of Regulation M-A. Additionally, confirm that you will
disseminate offer
 materials that include the referenced financial statement information.
Offer to Purchase -- Conditions of the Offer, page 34

3. We note that the tender offer is conditioned on the closing of the
Transactions and that
 the Transactions are conditioned on the closing of the tender offer.
Please revise your
 disclosure to describe when and how the determination of the
satisfaction of the tender
 offer condition will be made.
4. We note that you have reserved the right to assert the occurrence of any
of the conditions
 to the offer at any time and from time to time. Defining the
conditions as an ongoing
 right that may be asserted at any time and from time to time suggests
that conditions to
 the offer may be raised or asserted after expiration of the offer.
Please be advised that all
 conditions to the offer, other than those subject to applicable law,
must be satisfied or
 waived before the expiration of the offer. Revise the disclosure to make
clear that all
 conditions, other than those subject to government approvals, will be
satisfied or waived
 on or before expiration of the offer.
5. Refer to the disclosure in the penultimate paragraph of this section
relating to your
 failure to exercise any of the rights described in this section. This
language indicates that
 once an offer condition is triggered, you may assert it at any time and
from time to time.
 Note that when a condition is triggered and you decide to proceed with
the offer anyway,
 we believe that this constitutes a waiver of the triggered condition(s).
Depending on the
 materiality of the waived condition and the number of days remaining in
the offer, you
 may be required to extend the offer and recirculate new disclosure to
security holders.
 You may not, as this language seems to imply, simply fail to assert a
triggered offer
 condition and thus effectively waive it without officially doing so.
Please confirm your
 understanding supplementally.
 We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.

 Please direct any questions to Daniel Duchovny at 202-551-3619.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers
& Acquisitions
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