January 13, 2020

Vicente Reynal
Chief Executive Officer
Gardner Denver Holdings, Inc.
222 East Erie Street, Suite 500
Milwaukee, WI 53202

       Re: Gardner Denver Holdings, Inc.
           Registration Statement on Form S-4
           Filed December 30, 2019
           File No. 333-235748

Dear Mr. Reynal:

       We have reviewed your registration statement and have the following
comment. In our
comment, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comment applies to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to the comment, we may have additional comments.

Registration Statement on Form S-4 Filed on December 30, 2019

Exhibits

1.     Please provide revised tax opinions for Exhibits 8.1 and 8.2 that opine
on the material tax
       consequences of the transactions. Currently, these opinions provide a
legal conclusion as
       it relates to one or more Internal Revenue Code provisions, but opine on
the accuracy of
       the disclosure in the registration statement rather than the material
tax consequences. For
       guidance, please refer to Section III.C.1 and 2 of CF Staff Legal
Bulletin No. 19.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 Vicente Reynal
Gardner Denver Holdings, Inc.
January 13, 2020
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Joseph Cascarano, Staff Accountant, at (202) 551-3376
or Lisa Haynes
Etheredge, Staff Accountant, at (202) 551-3424 if you have questions regarding
comments on
the financial statements and related matters. Please contact Edwin Kim, Staff
Attorney, at (202)
551-3297 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other
questions.



FirstName LastNameVicente Reynal                            Sincerely,
Comapany NameGardner Denver Holdings, Inc.
                                                            Division of
Corporation Finance
January 13, 2020 Page 2                                     Office of
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FirstName LastName