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May 7, 2020
Vivek Sankaran
Chief Executive Officer
Albertsons Companies, Inc.
250 Parkcenter Blvd.
Boise, ID 83706
Re:Albertsons Companies, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed May 5, 2020
File No. 333-236956
Dear Mr. Sankaran:
            We have reviewed your amended registration statement and have the following
comment.  In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our March 18, 2020 letter.
Amendment No.1 to Registration Statement on Form S-1
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
57
1.We note your disclosure that as a result of COVID-19 “identical sales increased 47%
during the first four weeks of fiscal 2020 (ending March 28, 2020), and increased 21%
during the second four weeks of fiscal 2020 (ending April 25, 2020). Identical sales for
the first eight weeks of fiscal 2020 increased 34% compared to the comparable period
during fiscal 2019. As a result, our cash balance as of April 25, 2020 was approximately
$4.0 billion, which includes the proceeds from the ABL Borrowing, and our Net Debt as
of April 25, 2020 was approximately $6.7 billion.” To contextualize the significance of
these percentages for investors, please consider quantifying identical sales for the first

 FirstName LastNameVivek Sankaran
 Comapany NameAlbertsons Companies, Inc.
 May 7, 2020 Page 2
 FirstName LastName
Vivek Sankaran
Albertsons Companies, Inc.
May 7, 2020
Page 2
four and eight weeks of fiscal 2019 and your cash balance and Net Debt for the equivalent
period in fiscal 2019. In this regard, we note that you have only provided identical sales,
Net Debt and cash balances on an annual basis for prior financial periods. As a related
matter, please also discuss the impact of COVID-19 on financial statement measures,
other than cash balance, to provide additional context for investors. In this regard, a single
financial measure, such as cash, may be considered an incomplete picture of your results
of operation or financial condition.  Please refer to CF Disclosure Guidance: Topic No. 9
(March 25, 2020).
            You may contact Jennifer Lopez, at 202-551-3792, or Lilyanna Peyser, at 202-551-
3222, with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services