United States securities and exchange commission logo





                             January 14, 2021

       Ralph Nicoletti
       Senior Vice President
       AZEK Co Inc.
       1330 W Fulton Street #350
       Chicago, IL 60607

                                                        Re: AZEK Co Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted January
11, 2021
                                                            CIK No. 0001782754

       Dear Mr. Nicoletti:

                                                        This is to advise you
that we do not intend to review your registration statement.

               We request that you publicly file your registration statement no
later than 48 hours prior
       to the requested effective date and time. Please refer to Rules 460 and
461 regarding requests for
       acceleration. 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.

                                                        Please contact Erin
Purnell at 202-551-3454 with any questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Manufacturing