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 July 28, 2025

Asna Afzal
Principal Executive Officer
Beach Acquisition Co Parent, LLC
c/o 3G Capital Partners L.P.
600 Third Avenue, 37 Floor
New York, New York 10016

 Re: Beach Acquisition Co Parent, LLC
 Amendment No. 1 to Registration Statement on Form S-4
 Filed July 14, 2025
 File No. 333-287891
Dear Asna Afzal:

 We have reviewed your amended registration statement and have the
following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment 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 letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our July 8, 2025
letter.

Amendment No. 1 to Registration Statement on Form S-4
Cover Page

1. We note your revisions in response to prior comment 6. Please reconcile
your
 disclosure on the cover page that the Greenberg Stockholders would own
 approximately 3.8% and 15.5% of the beneficial ownership and voting
power of
 Parent under the scenarios presented, with your other disclosure on
pages 4 and 20
 that they would own the same percentages of the issued and outstanding
Parent Units.
 In this regard, we note your capital structure and the nature of the
disparate voting
 rights of the Common Units and Class P Units.
 July 28, 2025
Page 2
Summary, page 17

2. We note your revisions in response to prior comment 9. Please revise
throughout to
 clarify how your Class P Units are entitled to 2.9655 votes per Class P
Unit yet such
 voting rights are the equivalent of one vote for each Common Unit. In
this regard, we
 note that this appears inconsistent with Section 2.01 of the Parent A&R
LLCA, which
 states that each Common Unit will be entitled to one vote, while each
Class P Unit
 shall be equivalent to 2.9655 Common Units.
Merger
Background of the Transaction, page 62

3. We note your revisions in response to prior comment 16. Please address
the part of
 that comment that requests revisions to discuss the Debt Financing and
Equity
 Financing and the need to obtain additional financing for the Parent in
this section.
Recommendations of the Independent Committee and the Skechers Board; Skechers'
Reasons
for the Transaction, page 78

4. We note your revisions in response to prior comment 22. In the listing
of factors on
 page 78, please discuss whether the Board and the Independent Committee
considered
 the determination not to obtain a fairness opinion for the Mixed
Election
 Consideration as a negative factor.
Directors and Management of Parent After Completion of the Transaction, page
140

5. We note your revisions in response to prior comment 32. Please address
the part of
 that comment that requests information required by Item 19(a)(7) of Form
S-4. In this
 regard, please briefly discuss the specific experience, qualifications,
attributes or skills
 that led to the conclusion that Alexandre Behring and Daniel Schwartz
should serve as
 your directors. Further, please provide the information required by
Items 402, 404 and
 407(a) of Regulation S-K for these individuals.
Ownership of Parent After the Merger, page 151

6. We note your revisions in response to prior comment 33. Please revise to
comply with
 Item 403 of Regulation S-K. Refer to Item 19(a)(5) of Form S-4. In this
regard, please
 consider presenting tables assuming that (i) all holders of Legacy
Shares elect the
 Mixed Election Consideration and (ii) no holders of Legacy shares elect
the Mixed
 Election Consideration. Please include separate columns for (a) Common
Units, (b)
 Class P Units and (c) total Parent Units that reflect both the expected
 beneficial ownership of such securities and total voting power.
Material United States Federal Income Tax Consequences, page 152

7. We note your disclosure that Skechers and Parent intend that for U.S.
federal income
 tax purposes, with respect to holders of Skechers Common Stock who elect
to receive
 Mixed Election Consideration for any or all of their shares, the Merger
qualify as a
 transaction described in Section 351 of the Code. Please revise your
disclosure to
 clearly identify and articulate the opinions being rendered as to the
material federal
 tax consequences. If there is uncertainty regarding the tax treatment of
the
 transactions, counsel may issue a "should" or "more likely than not"
opinion to make
 July 28, 2025
Page 3

 clear that the opinion is subject to a degree of uncertainty, and
explain why it cannot
 give a "will" opinion. Please provide appropriate risk factor and/or
other disclosure
 setting forth the risks of uncertain tax treatment to investors. Refer
to Staff Legal
 Bulletin No. 19. Please revise to disclose that such discussion is the
opinion of
 Latham & Watkins LLP.
Item 21. Exhibits and Financial Statement Schedules, page II-3

8. We note that the financial advisor s consent, previously filed as
Exhibit 23.5, states
 that it does not cover any future amendments to the Registration
Statement. Please
 have your financial advisor update its consent to also cover your
amended registration
 statement filed on July 14, 2025.
 Please contact Beverly Singleton at 202-551-3328 or Kevin Stertzel at
202-551-3723
if you have questions regarding comments on the financial statements and
related
matters. Please contact Jenny O'Shanick at 202-551-8005 or Asia Timmons-Pierce
at 202-
551-3754 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Steven B. Stokdyk
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