2005 East Indian School Road
Phoenix, Arizona 85016
September 13, 2021
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington D.C. 20549
Attention: Stacy Peikin
Registration Statement on Form S-1 (File No. 333-259475)
Dear Ms. Peikin:
Leslies, Inc., a Delaware corporation (the Company), respectfully requests pursuant to Rule 461 under the Securities Act of 1933, as amended, that the effective date of the Companys Registration Statement on Form S-1 (File No. 333-259475) (the Registration Statement) be accelerated and that it be declared effective September 14, 2021 at 5:30 p.m. Eastern time, or as soon as practicable thereafter, unless we or our outside counsel, Gibson, Dunn & Crutcher LLP, request by telephone that such Registration Statement be declared effective at some other time.
Please direct any questions regarding this filing to Peter Wardle of Gibson, Dunn & Crutcher LLP at (213) 229-7242.
/s/ Steven M. Weddell
Steven M. Weddell
Executive Vice President and Chief Financial Officer
Michael Egeck, Chief Executive Officer
Brad Gazaway, Chief Legal Officer
Peter Wardle, Esq.
Stelios Saffos, Esq.