United States securities and exchange commission logo September 8, 2021 Brad Gazaway Chief Legal Officer Leslie's, Inc. 2005 East Indian School Road Phoenix, Arizona 85016 Re: Leslie's, Inc. Draft Registration Statement on Form S-1 Submitted on September 1, 2021 File No. 377-05437 Dear Mr. Gazaway: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours 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 Stacey Peikin at 202-551-6223 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services