Paragon 28, Inc.
14445 Grasslands Drive
Englewood, CO 80112
October 12, 2021
VIA EDGAR TRANSMISSION
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Ibolya Ignat, Lynn Dicker, Jane Park and Laura Crotty
| Re: | Paragon 28, Inc. |
Registration Statement on Form S-1 (File No. 333-259789) |
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-1, as amended (File No. 333-259789) (the “Registration Statement”) of Paragon 28, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on October 14, 2021, or as soon as practicable thereafter, or at such later time as the Company may orally request via telephone call to the staff of the U.S. Securities and Exchange Commission (the “Commission”). Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Phillip Stoup at (415) 395-8216 or, in his absence, Shayne Kennedy at (714) 755-8181.
Thank you for your assistance in this matter.
Very truly yours,
| Paragon 28, Inc. | ||
| By: | /s/ Albert DaCosta | |
Albert DaCosta Chief Executive Officer | ||
| cc: | B. Shayne Kennedy, Latham & Watkins LLP |
Phillip Stoup, Latham & Watkins LLP |
