4525 Ayers Street
Corpus Christi, TX 78415
(361) 884-2463
www.susser.com
October 19, 2011
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Mr. Charles Lee
| Re: | Susser Holdings Corporation, and co-registrants |
Registration Statement on Form S-3
File No. 333-177265
Dear Sirs:
We refer to the registration statement on Form S-3 (File No. 333-177265) (as amended, the “Registration Statement”) of Susser Holdings Corporation (the “Company”), Susser Holdings, L.L.C. (“Susser Holdings”), Susser Finance Corporation (“Susser Finance”) and certain direct and indirect subsidiaries of the Company (the “Guarantors” and, together with the Company, Susser Holdings and Susser Finance, the “Applicants”), relating to the registration of the Company’s common stock, par value $0.01 per share, the debt securities of the Company or of Susser Holdings and Susser Finance and any guarantee of such debt securities.
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Applicants hereby respectfully request that the effectiveness of the Registration Statement be accelerated so that it may become effective at 4:30 PM (Eastern time) on Friday, October 21, 2011, or as soon as practicable thereafter.
The Applicants hereby each acknowledge the following:
1. Should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
2. The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve any Applicant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
3. The Applicants may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, each Applicant hereby confirms that it is aware of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, with respect to the proposed public offering of the securities specified in the Registration Statement.
Please call our counsel, Matthew Bloch of Weil, Gotshal & Manges LLP, at (212) 310-8165 to confirm the effectiveness of the Registration Statement or with any questions.
Very truly yours,
Susser Holdings Corporation; Susser Holdings, L.L.C; Susser Finance Corporation; and APT Management Company, LLC, as General Partner of Applied Petroleum Technologies, Ltd APT Management Company, LLC C&G Investments, LLC Corpus Christi Reimco, LLC GoPetro Transport LLC Stripes Acquisition LLC Stripes Holdings LLC Stripes LLC Stripes No. 1009 LLC Susser Financial Services LLC Susser Petroleum Company LLC T&C Wholesale, Inc. TCFS Holdings, Inc. Town & Country Food Stores, Inc. | ||
| By: | /s/ E.V. Bonner, Jr. | |
| E. V. Bonner, Jr. | ||
| Executive Vice President | ||
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| Quick Stuff of Texas, Inc. | ||
| By: | /s/ E.V. Bonner, Jr. | |
| E. V. Bonner, Jr. | ||
| President, Secretary and Treasurer | ||
SSP BevCo I LLC SSP BevCo II LLC SSP Beverage, LLC TND Beverage, LLC | ||
| By: | /s/ E.V. Bonner, Jr. | |
| E. V. Bonner, Jr. | ||
| Manager | ||
| cc: | Mr. Sam L. Susser, Chief Executive Officer |
Mr. Matthew D. Bloch, Weil, Gotshal & Manges LLP
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