SecProbe.io

CORRESP
 1
 filename1.htm

 Janus Living, Inc.

 4600 South Syracuse Street,
Suite 500

 Denver, CO 80237

 June 1, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:
 Howard Efron

 Kristina Marrone

 Stacie Gorman

 Pamela Long

 Re:
 Janus Living, Inc.

 Registration Statement on Form S-11, as amended
 (File No. 333-296384)

 Request for Acceleration of Effective Date

 To the addressees set forth above:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended, Janus Living, Inc. (the " Company ")
hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-11 (File No. 333-296384 )
(as amended, the " Registration Statement "). The Company respectfully requests that the Registration Statement
become effective as of 4:00 p.m., Eastern Time, on June 2, 2026, or as soon as practicable thereafter, or at such other time as
the Company or its legal counsel may request by telephone to the staff of the Division of Corporation Finance of the Securities and Exchange
Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham &
Watkins LLP, by calling Lewis Kneib at (213) 891-7339.

 Thank you for your assistance in this matter.

 [ Signature page follows ]

 Sincerely,

 Janus Living, Inc.

 By:
 /s/
 Scott M. Brinker

 Name:
 Scott M. Brinker

 Title:
 President and Chief Executive Officer

 cc:
 Kelvin O. Moses, Healthpeak Properties, Inc.

 Tracy A. Porter, Esq., Healthpeak Properties, Inc.

 Lewis W. Kneib, Esq. , Latham & Watkins
 LLP

 Charles K. Ruck, Esq., Latham & Watkins
 LLP

 Julian T.H. Kleindorfer, Esq., Latham &
 Watkins LLP

 Devon L. MacLaughlin, Esq., Latham &
 Watkins LLP

 Edward F. Petrosky, Esq., Sidley Austin LLP

 J. Gerard Cummins, Esq., Sidley Austin LLP

 Adam M. Gross, Esq., Sidley Austin LLP

 [ Signature Page to Acceleration Request ]

CORRESP
 1
 filename1.htm

 June 1, 2026

 Division of Corporation Finance

 Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 Re: Janus Living, Inc.
Registration Statement on Form S-11
File No. 333-296384

 Dear Ladies and Gentlemen:

 In connection with the proposed offering of the securities under the
above-captioned Registration Statement on Form S-11 (the " Registration Statement ") and pursuant to Rule 461 under the
Securities Act of 1933, as amended (the " Securities Act "), we wish to advise you that we, as representatives of the
underwriters, hereby join with Janus Living, Inc.'s request that the effective date of the Registration Statement be accelerated
so that the same will become effective on June 2, 2026 at 4:00 P.M., Eastern Time, or as soon as practicable thereafter.

 Pursuant to Rule 460 under the Securities Act, we, as representatives
of the several underwriters, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary
prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the above-referenced Registration
Statement.

 We, the undersigned, as representatives of the several underwriters,
will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 [ Signature Page Follows ]

 Sincerely,

 BofA Securities, Inc.

 J.P. Morgan Securities
 LLC

 RBC Capital Markets,
 LLC

 Wells Fargo Securities,
 LLC

 As Representatives of the several
 Underwriters

 BOFA SECURITIES, INC.

 By:
 /s/ Gray Hampton

 Name:
 Gray Hampton

 Title:
 Vice Chairman

 J.P. MORGAN SECURITIES LLC

 By:
 /s/ Grace Schlesinger

 Name:
 Grace Schlesinger

 Title:
 Vice President

 RBC Capital Markets, LLC

 By:
 /s/ Asad Kazim

 Name:
 Asad Kazim

 Title:
 Managing Director

 Group Head, U.S. Real Estate

 Wells Fargo Securities, LLC

 By:
 /s/ Rohit Mehta

 Name:
 Rohit Mehta

 Title:
 Managing Director

 [ Signature Page to UW Acceleration Request ]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 28, 2026

Scott Brinker
Chief Executive Officer
Janus Living, Inc.
4600 South Syracuse Street
Suite 500
Denver, CO 80237

 Re: Janus Living, Inc.
 Draft Registration Statement on Form S-11
 Submitted May 21, 2026
 CIK No. 000210080
Dear Scott Brinker:
 This is to advise you that we do not intend to review your registration
statement.
 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
Please refer to Rules 460 and 461 regarding requests for acceleration. We
remind you that the
company and its management are responsible for the accuracy and adequacy of
their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
 Please contact Stacie Gorman at 202-551-3585 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Lewis W. Kneib, Esq.
</TEXT>
</DOCUMENT>