TEXT-EXTRACT 2 filename2.txt November 27, 2018 David Yawman Executive Vice President, Government Affairs, General Counsel PepsiCo, Inc. 700 Anderson Hill Road Purchase, NY 10577 Re: PepsiCo, Inc. Registration Statement on Form S-4 Filed November 19, 2018 File No. 333-228466 Dear Mr. Yawman: This is to advise you that we have not reviewed and will not review your registration statement. 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 Ronald E. Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining cc: Joseph A. Hall