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SEC Company Response from BERRY GLOBAL GROUP, INC. (BERY) (CIK 0001378992) — Sep 16, 2021

BERRY GLOBAL GROUP, INC. (BERY) (CIK 0001378992)
Date: Sept. 16, 2021 · CIK: 0001378992 · Accession: 0001104659-21-116438

AI Filing Summary & Sentiment

File numbers found in text: 333-259272

Date
September 16, 2021
Author
Not clearly detected
Form
CORRESP
Company
BERRY GLOBAL GROUP, INC. (BERY) (CIK 0001378992)

Letter

Berry Global, Inc.

a wholly owned subsidiary of

Berry Global Group, Inc.

101 Oakley Street

Evansville, Indiana 47710

September 16, 2021

Via Edgar

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Gregory Herbers

Re: Berry Global, Inc.

Registration Statement on Form S-4 filed September 2, 2021

Registration No. 333-259272

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, and in connection with the captioned registration statement (the “Registration Statement”), Berry Global, Inc. (the “Company”), Berry Global Group, Inc. (“Berry”) and the subsidiary guarantors described in the Registration Statement (the “Subsidiary Guarantors”) hereby request that the Registration Statement be permitted to become effective on September 20, 2021 at 4:00 p.m., Eastern Time, or as soon thereafter as practicable.

In requesting acceleration of effectiveness of the Registration Statement, the Company, Berry and the Subsidiary Guarantors acknowledge that:

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

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

(iii) the Company, Berry and the Subsidiary Guarantors 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.

[Remainder of the page intentionally left blank]

If you have any questions or comments, please do not hesitate to contact me at (812) 306-2764 or Tyler F. Mark, Esq. at (303) 866-0238.

Berry Global, Inc.

and the Subsidiary Guarantors

By: /s/ Jason K. Greene

Jason K. Greene

Executive Vice President, General Counsel and Secretary

Berry Global Group, Inc.

By: /s/ Jason K. Greene

Jason K. Greene

Executive Vice President, Chief Legal Officer and Secretary

Cc: Tyler F. Mark, Esq.

Bryan Cave Leighton Paisner LLP

Show Raw Text
CORRESP
1
filename1.htm

Berry
Global, Inc.

a wholly
owned subsidiary of

Berry
Global Group, Inc.

101 Oakley Street

Evansville, Indiana 47710

September 16, 2021

Via Edgar

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Gregory Herbers

  Re:
  Berry Global, Inc.

  Registration Statement on Form S-4 filed September 2, 2021

Registration No. 333-259272

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended, and in connection with the captioned registration statement (the “Registration Statement”),
Berry Global, Inc. (the “Company”), Berry Global Group, Inc. (“Berry”) and the subsidiary guarantors described
in the Registration Statement (the “Subsidiary Guarantors”) hereby request that the Registration Statement be permitted to
become effective on September 20, 2021 at 4:00 p.m., Eastern Time, or as soon thereafter as practicable.

In requesting acceleration
of effectiveness of the Registration Statement, the Company, Berry and the Subsidiary Guarantors acknowledge that:

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

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

(iii) the Company, Berry and
the Subsidiary Guarantors 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.

[Remainder of the page intentionally left blank]

If you have any questions
or comments, please do not hesitate to contact me at (812) 306-2764 or Tyler F. Mark, Esq. at (303) 866-0238.

  Berry Global, Inc.

  and the Subsidiary Guarantors

  By:
  /s/ Jason K. Greene

  Jason K. Greene

  Executive Vice President, General Counsel and Secretary

  Berry Global Group, Inc.

  By:
  /s/ Jason K. Greene

  Jason K. Greene

  Executive Vice President, Chief Legal Officer and Secretary

  Cc:
  Tyler F. Mark, Esq.

  Bryan Cave Leighton Paisner LLP