United States securities and exchange commission logo

                             December 2, 2020

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

                                                        Re: PET Acquisition LLC
                                                            Amendment No. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted on
November 20, 2020
                                                            CIK No. 0001826470

       Dear Mr. Eskenazi:

             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

             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

       Amended Draft Registration Statement submitted on November 20, 2020

       Summary, page 1

   1.                                                   Please revise the
prospectus summary to clarify that no public stockholders will be
                                                        eligible to convert the
Class A shares.
       Our Sponsors, page 13

   2.                                                   We note your response
to prior comment 2. We note that the merger in January 2016 was
                                                        partially financed by
the private placement of the Floating Rate Senior Notes. Please
                                                        disclose the portion of
the transaction funded by the Floating Rate Senior Notes, quantify
                                                        the remainder of the
transaction amount, and disclose how the remainder of the
                                                        transaction was
financed. In addition, please explain the relationship of Pet Animal
 Ilene Eskenazi
PET Acquisition LLC
December 2, 2020
Page 2
      Supplies to your company. Please also identify the other sponsors that
participated in the
      merger transaction and disclose the parties' holdings upon completion of
the merger. In
      this regard, we note that your references to certain co-investors and
certain noteholders are
Principal Stockholders, page 151

3.     Please disclose the natural person(s) possessing investment and/or
voting power over the
      shares held by the entities listed in your principal stockholders table.
       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 2, 2020 Page 2
cc:       Andrew Fabens
FirstName LastName