SEC Company Response from GLOBAL PARTNERS LP (GLP, GLP-PB) (CIK 0001323468) (GLP) — Sep 26, 2005

GLOBAL PARTNERS LP (GLP, GLP-PB) (CIK 0001323468)
Date: Sept. 26, 2005 · CIK: 0001323468 · Accession: 0001104659-05-045735

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AI Filing Summary & Sentiment

File numbers found in text: 333-124755

Date

September 26, 2005

Author

PARTNERS LP

Form

CORRESP

Company

GLOBAL PARTNERS LP (GLP, GLP-PB) (CIK 0001323468)

Letter

VIA EDGAR & FACSIMILE TO (202) 772-9369 Division of Corporation Finance United States Securities and Exchange Commission Re: Global Partners LP Registration Statement on Form S-1 File No. 333-124755

Dear Mr. Wynn:

In connection with the acceleration request letter filed by Global Partners LP on September 23, 2005 regarding acceleration of the effectiveness of the above-referenced Registration Statement on Form S-1, Global Partners LP hereby acknowledges that:

• 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;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Global Partners LP from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• Global Partners LP 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.

Very truly yours,
GLOBAL
PARTNERS LP

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CORRESP
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GLOBAL PARTNERS LP

P.O. Box 9161

800 South Street

Waltham, Massachusetts 02454-9161

(781) 894-8800

September 26, 2005

VIA EDGAR
& FACSIMILE TO (202) 772-9369

Mr. Jason Wynn

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.
20549-7010

  Re:

  Global Partners LP

  Registration Statement on Form S-1

  File No. 333-124755

Dear Mr. Wynn:

In connection with the acceleration request letter
filed by Global Partners LP on September 23, 2005 regarding acceleration of the
effectiveness of the above-referenced Registration Statement on Form S-1,
Global Partners LP hereby acknowledges that:

•                  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;

•                  the action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the filing effective, does not
relieve Global Partners LP from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and

•                  Global Partners LP 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.

  Very truly yours,

  GLOBAL
  PARTNERS LP

  By:

  Global GP LLC

   its General Partner

  By:

    /s/ Edward J. Faneuil

  Edward J. Faneuil

  Executive Vice President,

  General Counsel and Secretary

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