Bumble Bee Foods, LLC
Connors Bros. Clover Leaf Seafoods Company
Bumble Bee Capital Corp.
9655 Granite Ridge Drive
San Diego, CA 92123
August 16, 2010
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Mail Stop: 3561
| | Registration Statement on Form S-4 |
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned Registrants hereby request that the effectiveness of the above-captioned Registration Statement be accelerated so that it will become effective as of 4:00 p.m. on August 16, 2010, or as soon thereafter as practicable.
The Registrants acknowledge that:
1. should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
2. the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
3. the Registrants 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.
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Very truly yours, |
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BUMBLE BEE FOODS, LLC |
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By: | | /s/ Christopher Lischewski |
| | Name: Christopher Lischewski |
| | Title: President and Chief Executive Officer |
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CONNORS BROS. CLOVER LEAF SEAFOODS COMPANY |
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By: | | /s/ Christopher Lischewski |
| | Name: Christopher Lischewski |
| | Title: President |
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BUMBLE BEE CAPITAL CORP. |
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By: | | /s/ Christopher Lischewski |
| | Name: Christopher Lischewski |
| | Title: President and Chief Executive Officer |