The Benchmark Company LLC
150 East 58th Street, 17th Floor
New York, New York 10155
VIA EDGAR
August 9, 2023
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Sacks Parente Golf, Inc. (“Company”) |
| | Registration Statement on Form S-1, as amended |
| | File No. 333-266610 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as representatives of the several underwriters of the Company’s proposed initial public offering, hereby join the Company’s request that the effective date of the above-referenced Registration Statement be accelerated so that the above-referenced Registration Statement will be declared effective at 4:30 p.m., Eastern Time, on Friday, August 11, 2023, or as soon as practicable thereafter.
Pursuant to Rule 460 under the Securities Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each Underwriter or dealer, who is reasonably anticipated to participate in the distribution of the securities, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
| Very truly yours, |
| |
| The Benchmark Company, LLC |
| |
| By: | /s/ Michael Jacobs |
| Name: | Michael Jacobs |
| Title: | Managing Director |