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CORRESP Filing

SONIDA SENIOR LIVING, INC.
Date: Jan. 2, 2026 · CIK: 0001043000 · Accession: 0001193125-26-000350

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File numbers found in text: 333-292187

Date
January 2, 2026
Author
Tabitha T. Bailey
Form
CORRESP
Company
SONIDA SENIOR LIVING, INC.

Letter

Re: Sonida Senior Living, Inc. Registration Statement on Form S-4 File No. 333-292187 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Sonida Senior Living, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above referenced Registration Statement on Form S-4 to 9:00 a.m., Eastern Time, on January 6, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Fried, Frank, Harris, Shriver & Jacobson LLP request by telephone that such Registration Statement be declared effective. Please contact Philip Richter, Esq. of Fried, Frank, Harris, Shriver & Jacobson LLP at (212) 859-8763 or by email at Philip.Richter@friedfrank.com or Erica Jaffe, Esq. of Fried, Frank, Harris, Shriver & Jacobson LLP at (212) 859-8442 or by email at Erica.Jaffe@friedfrank.com, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

Acceleration Request

SONIDA SENIOR LIVING, INC. 14755 Preston Rd, Ste 810 Dallas, TX 75254 January 2, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549

Sincerely,
SONIDA SENIOR LIVING, INC.

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CORRESP
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 filename1.htm

 Acceleration Request

 SONIDA SENIOR LIVING, INC.
 14755 Preston Rd, Ste 810 Dallas,
TX 75254 January 2, 2026 VIA EDGAR
 United States Securities and Exchange Commission
 Division of Corporation Finance 100 F Street, N.E.
 Washington, D.C. 20549

 Re:
 Sonida Senior Living, Inc.
 Registration Statement on Form S-4
 File No. 333-292187
 Ladies and Gentlemen: Pursuant to Rule 461
under the Securities Act of 1933, as amended, Sonida Senior Living, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above referenced Registration Statement on Form S-4 to 9:00 a.m., Eastern Time, on January 6, 2025, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Fried, Frank, Harris, Shriver & Jacobson LLP
request by telephone that such Registration Statement be declared effective. Please contact Philip Richter, Esq. of Fried, Frank, Harris,
Shriver & Jacobson LLP at (212) 859-8763 or by email at Philip.Richter@friedfrank.com or Erica Jaffe, Esq. of Fried, Frank, Harris, Shriver & Jacobson LLP at (212) 859-8442 or by email at Erica.Jaffe@friedfrank.com, as soon as the registration statement has been declared effective, or if you have any other questions or concerns regarding this matter.

 Sincerely,

 SONIDA SENIOR LIVING, INC.

 /s/ Tabitha T. Bailey

 Tabitha T. Bailey

 Senior Vice President and Chief Legal Officer

 cc:

 Edward A. Deibert, Esq., Arnold & Porter Kaye Scholer LLP
 Therese Fox, Esq., Arnold & Porter Kaye Scholer LLP
 Brady Randall, Esq., Arnold & Porter Kaye Scholer LLP