425 LEXINGTON AVENUE

NEW YORK, NY 10017-3954

TELEPHONE: +1-212-455-2000

FACSIMILE: +1-212-455-2502

DIRECT DIAL NUMBER   (212) 455-7614 E-MAIL ADDRESS   elewandowski@stblaw.com

November 6, 2020

Re: TU TopCo, Inc.

Draft Registration Statement on Form S-1

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington D.C. 20549

Ladies and Gentlemen:

On behalf of TU TopCo, Inc. (the “Company”), we hereby confidentially submit a draft Registration Statement on Form S-1 (the “Registration Statement”), relating to the Company’s proposed offering of shares of its common stock, for non-public review by the Staff of the Securities and Exchange Commission (the “Commission”) prior to the public filing of the Registration Statement. The Company will publicly file its registration statement and non-public draft submissions at least 15 days prior to any road show.

In reliance on the June 29, 2017 announcement of the Commission’s Division of Corporation Finance, the Registration Statement does not include unaudited financial information as of and for the six months ended June 30, 2020 and 2019, as the Company believes such financial information will not be required to be presented separately at the time the Registration Statement is publicly filed.

Please do not hesitate to contact me at (212) 455-7614 or Joshua Ford Bonnie at (202) 636-5804 with any questions you may have regarding this confidential submission. Please send any correspondence to Jeffrey Chugg, Vice President, Legal (jeffrey.chugg@taskus.com) and to me (elewandowski@stblaw.com).

Very truly yours,

/s/ Edgar J. Lewandowski

Edgar J. Lewandowski

cc: TU TopCo, Inc.

Jeffrey Chugg