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                               July 23, 2021

       Jeremy Andrus
       Chief Executive Officer
       TGPX Holdings I LLC
       1215 E Wilmington Ave., Suite 200
       Salt Lake City, Utah 84106

                                                        Re: TGPX Holdings I LLC
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed July 21, 2021
                                                            File No. 333-257714

       Dear Mr. Andrus:

             We have reviewed your amended registration statement 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 July
13, 2021 letter.

       Form S-1 filed July 21, 2021

       Prospectus Summary
       Recent Developments
       Preliminary Estimated Financial Results for the Three Months and Six
Months Ended June 30,
       2021, page 12

   1.                                                   Please revise your
discussion of the preliminary estimated financial results for the three
                                                        months ended June 30,
2021 to disclose and discuss the factors that resulted in the
                                                        decrease in revenue and
decrease in gross profit margin relative to the financial results for
                                                        the three months ended
March 31, 2021. Please specifically address the decrease in
                                                        revenue in light of the
fact, that based on your disclosures on page 94, historically you
                                                        generated your highest
revenue during the second quarter in the last two fiscal years.
 Jeremy Andrus
TGPX Holdings I LLC
July 23, 2021
Page 2
Refinancing, page 15

2.    In regard to the Refinancing and the related pro forma disclosures
presented under
      Summary Consolidated Financial and Operating Data and Capitalization,
please address
      the following:
          Given your disclosure here that following the acquisition and the
Refinancing, as of
           July 2, 2021, the aggregate principal amount of your debt was
approximately $518
           million and your cash and cash equivalents were approximately $15
million, it
           appears to us you should revise the pro forma disclosures related to
cash and cash
           equivalents, working capital, and long term debt on pages 25 and 75
to reflect the
           cash used and debt incurred for the recent acquisition.
          Given your disclosures related to the adjustment for the debt
refinancing and interest
           expense on page 24, it appears to us you should separately reflect
each component of
           the adjustments so that potential shareholders can more readily
determine how the
           amounts included in the adjustments were determined.
Consolidated Financial Statements
12 - Subsequent Events, page F-40

3.    Please revise your subsequent event note to also disclose the terms and
estimated fair
      value of the Chief Executive Officer Award.
        You may contact Andi Carpenter, Staff Accountant, at (202) 551-3645 or
Anne
McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding
comments on
the financial statements and related matters. Please contact Sergio Chinos,
Staff Attorney, at
(202) 551-7844 or Erin Purnell, Staff Attorney, at (202) 551-3454 with any
other questions.



                                                           Sincerely,
FirstName LastNameJeremy Andrus
                                                           Division of
Corporation Finance
Comapany NameTGPX Holdings I LLC
                                                           Office of
Manufacturing
July 23, 2021 Page 2
cc:       Stelios Saffos
FirstName LastName