Berry Plastics Corporation
a wholly owned subsidiary of
Berry Plastics Group, Inc.
101 Oakley Street
Evansville, Indiana 47710
May 9, 2016
Via Edgar
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Frank Pigott
| Re: | Berry Plastics Corporation | |
| Registration Statement on Form S-4 filed May 2, 2016 | ||
| Registration No. 333-211076 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, and in connection with the captioned registration statement (the “Registration Statement”), Berry Plastics Corporation (the “Company”), Berry Plastics Group, Inc. (“Berry”) and the subsidiary guarantors described in the Registration Statement (the “Subsidiary Guarantors”) hereby request that the Registration Statement be permitted to become effective on May 12, 2016 at 9:00 a.m., Eastern Time, or as soon thereafter as practicable.
In requesting acceleration of effectiveness of the Registration Statement, the Company, Berry and the Subsidiary Guarantors acknowledge that:
(i) should the Securities and Exchange Commission (the “Commission”) or its staff (the “Staff”), acting pursuant to delegated authority, declare the filings effective, it does not foreclose the Commission from taking any action with respect to the filings;
(ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filings effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filings; and
(iii) the Company, Berry and the Subsidiary Guarantors 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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If you have any questions or comments, please do not hesitate to contact me at (812) 306-2764 or Terence A. Childers, Esq. at (404) 572-6820.
| Berry Plastics Corporation | ||
| and the Subsidiary Guarantors | ||
| By: | /s/ Jason K. Greene | |
| Jason K. Greene | ||
| Executive Vice President, General Counsel and Secretary | ||
| Berry Plastics Group, Inc. | ||
| By: | /s/ Jason K. Greene | |
| Jason K. Greene | ||
| Chief Legal Officer | ||
