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                             November 2, 2021

       Kevin Krumm
       Chief Financial Officer
       APi Group Corp
       1100 Old Highway 8 NW
       New Brighton, MN 55112

                                                        Re: APi Group Corp
                                                            Form 10-K for the
year ended December 31, 2020
                                                            Filed on March 24,
2021
                                                            Form 8-K filed on
August 11, 2021
                                                            File No. 001-39275

       Dear Mr. Krumm:

               We have reviewed your October 29, 2021 response to our comment
letter 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 comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to this comment, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       October 26, 2021 letter.

       Form 8-K filed on August 11, 2021

       General

   1.                                                   We note your response
to our comment. While it is noted that the step-up adjustment will
                                                        no longer be necessary
after September 30, 2021, due to the comparative nature of your
                                                        non-GAAP presentations
which include prior periods, it appears that such adjustment will
                                                        continue to be
presented in filings subsequent to your September 30, 2021 filings. Please
                                                        remove this adjustment
from all future filings including any filings reflecting comparative
                                                        periods that previously
included such an adjustment.
              You may contact Ameen Hamady at 202-551-3891 or in his absence,
Shannon Menjivar
       at 202-551-3856 if you have any questions.
 Kevin Krumm
APi Group Corp
November 2, 2021
Page 2




FirstName LastNameKevin Krumm   Sincerely,
Comapany NameAPi Group Corp
                                Division of Corporation Finance
November 2, 2021 Page 2         Office of Real Estate & Construction
FirstName LastName