ORRICK, HERRINGTON & SUTCLIFFE LLP THE ORRICK BUILDING 405 HOWARD STREET SAN FRANCISCO, CALIFORNIA
94105-2669   tel +1-415-773-5700 fax +1-415-773-5759 www.orrick.com   Brett Cooper 415-773-5918 bcooper@orrick.com

June 22, 2015

VIA EDGAR

Mara L. Ransom, Assistant Director

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re: Central Garden & Pet Company (and other noted additional registrants)

Registration Statement on Form S-3

Filed June 11, 2015, as amended

File No. 333-204881

Dear Ms. Ransom:

On behalf of Central Garden & Pet Company and the additional registrant guarantors noted in the Registration Statement, we are responding to your comment letter dated June 22, 2015. For ease of reference, we have included your comment and the company’s response.

Exhibit 5.1

1. Comment: With respect to the 2,866,073 shares of Class A common stock and 1,395,704 shares of common stock that are currently outstanding and being registered, please revise to also have counsel opine that these shares are currently outstanding and fully paid. Please see section II.B.2.h of Staff Legal Bulletin No. 19.

Response: We have filed a revised opinion to address the comment.

Mara L. Ransom

June 22, 2015

Page 2

If you have any questions, please contact me at 415-773-5918 or bcooper@orrick.com.

Very truly yours,

/s/ Brett Cooper

Brett Cooper

cc: John R. Ranelli – Chief Executive Officer

John F. Seegal