COMPASS GROUP DIVERSIFIED HOLDINGS LLC

301 Riverside Avenue

Second Floor

Westport, Connecticut 06880

(203) 221-1703

August 19, 2019

VIA EDGAR

Terence O'Brien

Accounting Branch Chief

Office of Manufacturing and Construction

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, North East

Washington, D.C. 20549-3561

Re: Compass Diversified Holdings

Form 10-K for the Fiscal Year Ended December 31, 2018

Filed: February 27, 2019

File No: 1-34927

Compass Group Diversified Holdings LLC

Form 10-K for the Fiscal Year Ended December 31, 2018

Filed: February 27, 2019

File No: 1-34926

Dear Mr. O’Brien,

On behalf of Compass Diversified Holdings (“Holdings”) and Compass Group Diversified Holdings LLC (the “Company”), set forth below is our response to the comment provided by the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in a letter dated August 15, 2019 relating to the above-captioned Form 10-K for the Fiscal Year Ended December 31, 2018 filed with the Commission on February 27, 2019 (the “Form 10-K”). For your convenience, we have set forth the Staff’s comments in bold, italic typeface followed by our response. References to “we,” “us,” “our” and “Registrant” refer to Holdings and the Company collectively. All other terms used herein and not otherwise defined shall have the meanings ascribed to such terms in the Form 10-K. All responses are those of Holdings and the Company only.

Form 10-K for the Fiscal Year Ended December 31, 2018

General

1. We note that you incorrectly tagged total net deferred tax liability with “us-gaap_DeferredTaxAssetsLiabilitiesNet” on the balance sheet as of December 31, 2018. Please use the appropriate tag in the U.S. GAAP taxonomy in future filings.

We confirm that we will comply with the Staff’s comment in future filings by revising our tagged total net deferred tax liability to use the appropriate tag in the U.S. GAAP taxonomy.

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We hope that you will find our response to the comment of the Commission’s Staff satisfactory. If further information regarding any aspect of this response letter is required, please contact Ryan J. Faulkingham at (203) 221-1703 or Toby D. Merchant at (513) 361-1200.

Sincerely,

/s/ Ryan J. Faulkingham

Ryan J. Faulkingham

Chief Financial Officer

cc: Ms. Kerri Tiernan, Compass Group Diversified Holdings LLC

Mr. Toby D. Merchant, Squire Patton Boggs (US) LLP

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