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                             March 1, 2021

       Eifion Jones
       Senior Vice President and Chief Financial Officer
       Hayward Holdings, Inc.
       400 Connell Drive
       Suite 6100
       Berkeley Heights, NJ 07922

                                                        Re: Hayward Holdings,
Inc.
                                                            Supplemental
Response to Registration Statement on Form S-1
                                                            Filed on February
26, 2021
                                                            File No. 333-253184

       Dear Mr. Jones:

             We have reviewed your supplemental response letter and have the
following
       comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
February 24, 2021 letter.

       Response letter dated February 26, 2021

       Summary Consolidated Financial and Other Data, page 22

   1.                                                   You state in your
response to prior comment 2 you do not deem it probable that the
                                                        conditions will be met
for the vesting of performance-based Class B options and restricted
                                                        stock awards. Please
explain further how you considered the pending registration
                                                        statement and the
estimated IPO price range in relation to the market performance criteria
                                                        in determining that
vesting was not probable for purposes of pro forma per share
                                                        information. In your
response, please provide us with the amount of compensation
                                                        expense that will be
recorded upon vesting and the impact on your pro forma per share
                                                        disclosures. Also,
ensure this information is included in the notes to your pro forma per
 Eifion Jones
Hayward Holdings, Inc.
March 1, 2021
Page 2
      share disclosures. Refer to Article 11-01(a)(8) of Regulation S-X.
Note 21. Subsequent Events, page F-38

2.    We note your response to prior comment 3. Please further revise here to
include an
      estimate of the impact that the January 2021 share-based payment awards
will have on
      your financial statements pursuant to ASC 855-10-50-2b.
        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.

       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 Brittany Ebbertt, Senior Staff Accountant, at (202)
551-3572 or
Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Michael Foland, Staff
Attorney, at (202) 551-6711 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                           Sincerely,
FirstName LastNameEifion Jones
                                                           Division of
Corporation Finance
Comapany NameHayward Holdings, Inc.
                                                           Office of Technology
March 1, 2021 Page 2
cc:       Rachel Phillips
FirstName LastName