TEXT-EXTRACT 2 filename2.txt October 16, 2019 Lance Mitchell Chief Executive Officer Reynolds Consumer Products Inc. 1900 W. Field Court Lake Forest, IL 60045 Re: Reynolds Consumer Products Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Filed Octoer 2, 2019 CIK No. 0001786431 Dear Mr. Mitchell: 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 response. 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 comments. DRS/A filed on October 2, 2019 Note 2 - Summary of Significant Accounting Policies Revenue Recognition , page F-12 1. You indicate that you estimate your transaction price using the most likely method. Please tell us why it is appropriate to apply this method rather than the expected value method given the characteristics of your contracts and the nature of your promotional activities. See ASC 606-10-32-8. You may contact Ameen Hamady at (202) 551-3891 or Al Pavot at (202) 551-3738 if you have questions regarding comments on the financial statements and related matters. Please contact Sherry Haywood at (202) 551-3345 or Asia Timmons-Pierce at (202) 551-3754 with any Lance Mitchell Reynolds Consumer Products Inc. October 16, 2019 Page 2 other questions. FirstName LastNameLance Mitchell Sincerely, Comapany NameReynolds Consumer Products Inc. Division of Corporation Finance October 16, 2019 Page 2 Office of Manufacturing FirstName LastName