United States securities and exchange commission logo

                              December 15, 2020

       Ilene Eskenazi
       General Counsel
       PET Acquisition LLC
       10850 Via Frontera
       San Diego, California 92127

                                                        Re: PET Acquisition LLC
Statement on Form S-1
                                                            Filed on December
3, 2020
                                                            File No. 333-251107

       Dear Mr. Eskenazi:

              We have reviewed your 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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1

       A Letter From PETCO, page iii

   1.                                                   Please balance your
statements about the company   s positive growth prospects with a
                                                        discussion of the risks
and obstacles you face, including the significant losses that you
                                                        have incurred and your
accumulated deficit. Please also remove statements that suggest
                                                        you are the only pet
care company that provides food, supplies, grooming, training, and
                                                        vet services in an
integrated fashion or provide the basis for this statement. Similarly,
                                                        please tell us how you
determined that you are making    massive, positive impacts    on
                                                        pets, parents, your
partners, and the communities you serve. Lastly, given that you
                                                        continue to operate in
the same industry and the customers you serve remain
                                                        fundamentally the same,
please remove the statement that you are a    profoundly new
 Ilene Eskenazi
PET Acquisition LLC
December 15, 2020
Page 2

        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

       You may contact Keira Nakada at (202) 551-3659 or Doug Jones at (202)
551-3309 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Morris at (202) 551-3314 or Lilyanna Peyser at (202) 551-3222
with any other

FirstName LastNameIlene Eskenazi
                                                           Division of
Corporation Finance
Comapany NamePET Acquisition LLC
                                                           Office of Trade &
December 15, 2020 Page 2
cc:       Andrew Fabens
FirstName LastName