United States securities and exchange commission logo May 18, 2021 Thomas Lydon Chief Financial Officer APi Group Corporation 1100 Old Highway 8 NW New Brighton, MN 55112 Re: APi Group Corp Registration Statement on Form S-3 Filed May 12, 2021 File No. 333-256049 Dear Mr. Lydon: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Ronald (Ron) E. Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Flora Perez