SecProbe.io

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January 10, 2025

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, D.C. 20549

 Re: Berry Global, Inc.

Registration Statement on Form S-4, as amended (File No. 333- 282333)

Ladies and Gentlemen:

In connection with the exchange
offers proposed by Berry Global, Inc. (the “Company”) pursuant to the prospectus contained in the above-referenced registration
statement and related letter of transmittal, this letter will confirm the following:

1.           The
Company is registering the exchange offers in reliance upon the position of the Staff of the Commission enunciated in the no-action letter
issued to Exxon Capital Holdings Corporation (available May 13, 1988).

2.           The
Company has not entered into any arrangement or understanding with any person to distribute the notes to be received in the exchange offers
(the “Registered Notes”) in exchange for the Company’s outstanding notes (the “Private Notes”) and, to the
best of the Company’s information and belief, each person participating in the exchange offers is acquiring the Registered Notes
in the ordinary course of its business, is not participating in and has no arrangement or understanding with any person to participate
in the distribution of the Registered Notes to be received in the exchange offers and is not an “affiliate” of the Company
within the meaning of Rule 405 under the Securities Act of 1933, as amended (the “Securities Act”). In this regard, the
Company will make each person participating in the exchange offers aware that if such person is participating in the exchange offers for
the purpose of distributing the Registered Notes to be acquired in the exchange offers, such person (i) could not rely on the Staff
position enunciated in Exxon Capital Holdings Corporation or interpretative letters to similar effect and (ii) must comply with the
registration and prospectus delivery requirements of the Securities Act in connection with any resale transaction, unless an exemption
from registration is otherwise available. The Company acknowledges that such a secondary resale transaction by such person participating
in the exchange offers for the purpose of distributing the Registered Notes should be covered by an effective registration statement containing
the selling security holder information required by Item 507 of Regulation S-K.

A broker-dealer may participate
in the exchange offers with respect to Private Notes acquired for its own account as a result of market-making or other trading activities
provided that the broker-dealer has not entered into any arrangement or understanding with the Company or an affiliate of the Company
to distribute the Registered Notes, and the Company (i) will make each person participating in the exchange offers aware (through
the exchange offers prospectus) that any broker-dealer who holds Private Notes acquired for its own account as a result of market-making
or other trading activities, and who receives Exchange Notes in exchange for such Private Notes pursuant to the exchange offers, may be
deemed to be an “underwriter” within the meaning of the Securities Act and must deliver a prospectus meeting the requirements
of the Securities Act as described in (2) above in connection with any resale of such Exchange Notes, and (ii) will include
in the transmittal letter to be executed by an exchange offeree in order to participate in the exchange offers a provision providing that
if the exchange offeree is a broker-dealer holding Private Notes acquired for its own account as a result of market-making or other trading
activities, an acknowledgement that it will deliver a prospectus meeting the requirements of the Securities Act in connection with any
resale of the Exchange Notes received in respect of such Private Notes pursuant to the exchange offers; however, by so acknowledging and
by delivering a prospectus, a broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of
the Securities Act.

U.S. Securities and Exchange Commission

Page 2

The transmittal letter to
be executed by the exchange offeree in order to participate in the exchange offers includes a representation to the effect that if the
exchange offeree is not a broker-dealer that by accepting the exchange offers, the exchange offeree represents that it is not engaged
in, and does not intend to engage in, a distribution of the Exchange Notes.

    Sincerely,

    /s/ Jason K.
    Greene

    Jason K. Greene

        Executive Vice President and General Counsel