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SEC Company Response from DXP ENTERPRISES INC (DXPE) (CIK 0001020710) (DXPE) — Sep 28, 2010

DXP ENTERPRISES INC (DXPE) (CIK 0001020710)
Date: Sept. 28, 2010 · CIK: 0001020710 · Accession: 0000950123-10-089745

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File numbers found in text: 333-166582

Date
September 28, 2010
Author
Mac McConnell
Form
CORRESP
Company
DXP ENTERPRISES INC (DXPE) (CIK 0001020710)

Letter

Re:

THE INDUSTRIAL DISTRIBUTION EXPERTS

September 28, 2010

DXP Enterprises, Inc.

Registration Statement on Form S-3

Registration No. 333-166582

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 7010

Washington, DC 20549

Attention:

Pamela A. Long, Assistant Director

Era Anagnosti, Staff Attorney

Ladies and Gentlemen:

The undersigned hereby requests that the effectiveness of its Registration Statement on Form S-3 (Registration No. 333-166582) be accelerated so that such Registration Statement will become effective at 4:00 p.m., EDT, on September 30, 2010, or as soon thereafter as practicable.

The undersigned acknowledges to the Securities and Exchange Commission (the “Commission”) that:

(a) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

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

(c) the undersigned may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please notify Laura J. McMahon of Fulbright & Jaworski L.L.P., counsel to DXP Enterprises, Inc., at (713) 651-5658 upon effectiveness of the Registration Statement or if you have any questions regarding this request.

Very truly yours,
DXP ENTERPRISES, INC.

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CORRESP
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corresp

    THE INDUSTRIAL DISTRIBUTION EXPERTS

September 28, 2010

    Re:

    DXP Enterprises, Inc.

Registration Statement on Form S-3

Registration No. 333-166582

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 7010

Washington, DC 20549

    Attention:

    Pamela A. Long, Assistant Director

Era Anagnosti, Staff Attorney

Ladies and Gentlemen:

     The undersigned hereby requests that the effectiveness of its Registration Statement on Form S-3
(Registration No. 333-166582) be accelerated so that such Registration Statement will become
effective at 4:00 p.m., EDT, on September 30, 2010, or as soon thereafter as practicable.

     The undersigned acknowledges to the Securities and Exchange Commission (the
“Commission”) that:

     (a) should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the Commission
from taking any action with respect to the filing;

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

     (c) the undersigned may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

     Please notify Laura J. McMahon of Fulbright & Jaworski L.L.P., counsel to DXP
Enterprises, Inc., at (713) 651-5658 upon effectiveness of the Registration Statement
or if you have any questions regarding this request.

    Very truly yours,

DXP ENTERPRISES, INC.

    By:

/s/ Mac McConnell

    Mac McConnell

    Senior Vice President/Finance
&
Chief Financial Officer

INNOVATIVE PUMPING SOLUTIONS   •   PRECISION SUPPLY CHAIN SERVICES   •   MROP SERVICE CENTERS

7272 Pinemont   •   Houston, TX 77040

Phone 713-996-4700   •   Fax 713-996-6570   •   Toll Free 800-830-3973