80 Grasslands Road
Elmsford, NY 10523
September 16, 2016
VIA EDGAR
Re: | Party City Holdco Inc. |
Form 10-K for the fiscal year ended December 31, 2015
Filed March 14, 2016
File No. 001-37344
Jennifer Thompson, Accounting Branch Chief
Lisa Sellars, Staff Attorney
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Dear Ms. Thompson and Ms. Sellars:
On behalf of Party City Holdco Inc. (the Company), I am responding to the comment letter from the staff of the Division of Corporation Finance (the Staff) of the Securities and Exchange Commission (the Commission) dated August 29, 2016 related to the Companys Annual Report on Form 10-K for the fiscal year ended December 31, 2015.
The Company hereby acknowledges that (i) it is responsible for the adequacy and accuracy of the disclosure in the filing, (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing, and (iii) it may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please do not hesitate to call Michael R. Littenberg at 212-596-9160 or William J. Michener at 617-951-7247, both of Ropes & Gray LLP, with any questions or further comments you may have.
Sincerely,
/s/ Daniel J. Sullivan
Daniel J. Sullivan
cc: | Michael A. Correale |
Michael R. Littenberg
William J. Michener