GLOBAL PARTNERS LP
P.O. Box 9161
800 South Street
Waltham, Massachusetts 02454-9161
(781) 894-8800
September 26, 2005
VIA EDGAR & FACSIMILE TO (202) 772-9369
Mr. Jason Wynn
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7010
Re: | Global Partners LP |
| Registration Statement on Form S-1 |
| File No. 333-124755 |
Dear Mr. Wynn:
In connection with the acceleration request letter filed by Global Partners LP on September 23, 2005 regarding acceleration of the effectiveness of the above-referenced Registration Statement on Form S-1, Global Partners LP hereby acknowledges that:
• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Global Partners LP from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
• Global Partners LP may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| Very truly yours, | ||
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| GLOBAL PARTNERS LP | ||
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| By: | Global GP LLC | |
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| its General Partner | |
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| By: | /s/ Edward J. Faneuil |
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| Edward J. Faneuil |
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| Executive Vice President, |
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| General Counsel and Secretary |
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