SPECTRUM BRANDS, INC.
3001 Deming Way
Middleton, Wisconsin 53562
June 18, 2019
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Spectrum Brands, Inc.
Registration Statement on Form S-1
(File No. 333-219844)
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, Spectrum Brands, Inc., a Delaware corporation (the Company) and certain of the Companys affiliates (together with the Company, the Registrants), hereby request that the effective date of the above-captioned Registration Statement on Form S-1 (the Registration Statement) be accelerated to June 20, 2019 at 4:00 p.m. Eastern time or as soon thereafter as may be practicable.
|U.S. Securities and Exchange Commission||2|
We understand that the Staff will consider this request as confirmation by each of the Registrants of its awareness of its responsibilities under the federal securities laws of the United States as they relate to the offer and sale of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Raphael M. Russo or Evan J. Cappelli of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3309 or (212) 373-3375, respectively.
|Spectrum Brands, Inc.|
|Applica Mexico Holdings, Inc.|
|Alaska Merger Acquisition Corp.|
|National Manufacturing Mexico A LLC|
|National Manufacturing Mexico B LLC|
|National Openings, LLC|
|Spectrum Brands Pet LLC|
|ROV Holding, Inc.|
|ROV International Holdings LLC|
|Salix Animal Health, LLC|
|SB/RH Holdings, LLC|
|Spectrum Brands Pet Group Inc.|
|United Industries Corporation|
|By:||/s/ Ehsan Zargar|
Executive Vice President, General Counsel, Secretary and/or Authorized Signatory,
Raphael M. Russo, Esq.
Paul, Weiss, Rifkind, Wharton & Garrison LLP