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                             September 3, 2021

       Bahram Akradi
       Chairman and Chief Executive Officer
       Life Time Group Holdings, Inc.
       2902 Corporate Place
       Chanhassen, Minnesota 55317

                                                        Re: Life Time Group
Holdings, Inc.
                                                            Amendment No. 2 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted August
27, 2021
                                                            CIK No. 0001869198

       Dear Mr. Akradi:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Summary Historical Consolidated Financial Information
       Adjusted EBITDA Reconciliation, page 21

   1.                                                   We note your response
to comment 7. We continue to believe that adjusting for "Pre-
                                                        opening expenses" is
not appropriate as these costs appear to be normal, recurring costs of
                                                        your operations. Please
remove your "Pre-opening expenses" adjustment from your non-
                                                        GAAP financial measure.
 Bahram Akradi
FirstName LastNameBahram    Akradi
Life Time Group Holdings, Inc.
Comapany 3,
September NameLife
             2021 Time Group Holdings, Inc.
September
Page 2    3, 2021 Page 2
FirstName LastName
Capitalization, page 56

2.       We note your revision in response to prior comment 9. Please tell us
why you have not
         made a pro forma adjustment for the amount of stock compensation that
will be
         recognized upon completion of this offering within your capitalization
table.
Management's Discussion and Analysis
Non-GAAP Measurements and Key Performance Indicators, page 63

3.       We note you include "non-cash rent expense" in your tabular
presentations on pages 63
         and 67. Please balance your disclosure by presenting the comparable
GAAP rent expense
         alongside the presentation of your "non-cash rent expense."
       You may contact Abe Friedman at 202-551-8298 or Joel Parker at
202-551-3651 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Donald Field at 202-551-3680 or Erin Jaskot at 202-551-3442 with any
other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services