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SEC Company Response from Bob's Discount Furniture, (BOBS) — Jan 9, 2026

Bob's Discount Furniture, Inc.
Date: Jan. 9, 2026 · CIK: 0002085187 · Accession: 0001628280-26-001456

Financial Reporting Regulatory Compliance Business Model Clarity

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Referenced dates: December 19, 2025

Date
January 9, 2026
Author
Rachel D. Phillips
Form
CORRESP
Company
Bob's Discount Furniture, Inc.

Letter

Document ROPES & GRAY LLP 1211 AVENUE OF THE AMERICAS NEW YORK, NY 10036-8704 WWW.ROPESGRAY.COM January 9, 2026 VIA EDGAR AND ELECTRONIC MAIL U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Nicholas Nalbantian Donald Field Ta Tanisha Meadows Rufus Decker Re: Bob’s Discount Furniture, Inc. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted December 8, 2025 CIK No. 002085187 Ladies and Gentlemen: On behalf of our client, Bob’s Discount Furniture, Inc. (the “ Company ”), we are filing with the Securities and Exchange Commission (the “ Commission ”), via EDGAR, the Registration Statement on Form S-1 (the “ Registration Statement ”), which reflects revisions to the above-referenced Amendment No. 2 to Draft Registration Statement confidentially submitted to the Commission on December 8, 2025. The Registration Statement has been revised to reflect responses to the comment letter addressed to the Company dated December 19, 2025 from the staff of the Commission (the “ Staff ”), as well as certain other updated information. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement. For reference purposes, the comment contained in the Staff’s letter dated December 19, 2025 is reproduced below in bold and the corresponding responses are shown below the comment. All references to page numbers in the Company’s responses are to the page numbers in the Registration Statement. Amendment No. 2 to Draft Registration Statement on Form S-1 General 1. Please refer to the “Bob’s by the numbers” gatefold graphic. Please revise to balance your net revenue disclosure with net income or loss information for the same period Division of Corporation Finance Securities and Exchange Commission January 9, 2025 Page 2 Response to Comment 1: The Company supplementally advises the Staff that it has revised its disclosure on the “Bob’s by the numbers” gatefold graphic in the Registration Statement in response to the Staff’s comment to include the requested net income information. * * * * * We hope that the foregoing has been responsive to the Staff’s comments. If you should have any questions about this letter or require any further information, please call the undersigned at (212) 841-8857 or my colleague, Craig Marcus, at (617) 951-7802. Thank you in advance for your assistance. Very truly yours, /s/ Rachel D. Phillips Rachel D. Phillips of Ropes & Gray LLP Enclosures cc: William G. Barton, Bob’s Discount Furniture, Inc. Carl Lukach, Bob’s Discount Furniture, Inc. Ryan Schaffer, Bob’s Discount Furniture, Inc. Craig E. Marcus, Ropes & Gray LLP Marc D. Jaffe, Latham & Watkins LLP Adam J. Geraldi, Latham & Watkins LLP 2

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CORRESP
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 Document ROPES & GRAY LLP 1211 AVENUE OF THE AMERICAS NEW YORK, NY 10036-8704 WWW.ROPESGRAY.COM January 9, 2026 VIA EDGAR AND ELECTRONIC MAIL U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Nicholas Nalbantian Donald Field Ta Tanisha Meadows Rufus Decker Re: Bob’s Discount Furniture, Inc. Amendment No. 2 to Draft Registration Statement on Form S-1 Submitted December 8, 2025 CIK No. 002085187 Ladies and Gentlemen: On behalf of our client, Bob’s Discount Furniture, Inc. (the “ Company ”), we are filing with the Securities and Exchange Commission (the “ Commission ”), via EDGAR, the Registration Statement on Form S-1 (the “ Registration Statement ”), which reflects revisions to the above-referenced Amendment No. 2 to Draft Registration Statement confidentially submitted to the Commission on December 8, 2025. The Registration Statement has been revised to reflect responses to the comment letter addressed to the Company dated December 19, 2025 from the staff of the Commission (the “ Staff ”), as well as certain other updated information. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Registration Statement. For reference purposes, the comment contained in the Staff’s letter dated December 19, 2025 is reproduced below in bold and the corresponding responses are shown below the comment. All references to page numbers in the Company’s responses are to the page numbers in the Registration Statement. Amendment No. 2 to Draft Registration Statement on Form S-1 General 1. Please refer to the “Bob’s by the numbers” gatefold graphic. Please revise to balance your net revenue disclosure with net income or loss information for the same period Division of Corporation Finance Securities and Exchange Commission January 9, 2025 Page 2 Response to Comment 1: The Company supplementally advises the Staff that it has revised its disclosure on the “Bob’s by the numbers” gatefold graphic in the Registration Statement in response to the Staff’s comment to include the requested net income information. *          *          *          *          * We hope that the foregoing has been responsive to the Staff’s comments. If you should have any questions about this letter or require any further information, please call the undersigned at (212) 841-8857 or my colleague, Craig Marcus, at (617) 951-7802. Thank you in advance for your assistance. Very truly yours, /s/ Rachel D. Phillips Rachel D. Phillips of Ropes & Gray LLP Enclosures cc: William G. Barton, Bob’s Discount Furniture, Inc. Carl Lukach, Bob’s Discount Furniture, Inc. Ryan Schaffer, Bob’s Discount Furniture, Inc. Craig E. Marcus, Ropes & Gray LLP Marc D. Jaffe, Latham & Watkins LLP Adam J. Geraldi, Latham & Watkins LLP 2