United States securities and exchange commission logo April 9, 2021 William Toler Chief Executive Officer HYDROFARM HOLDINGS GROUP, INC. 290 Canal Road Fairless Hills, Pennsylvania 19030 Re: HYDROFARM HOLDINGS GROUP, INC. Draft Registration Statement on Form S-1 Submitted April 2, 2021 CIK No. 0001695295 Dear Mr. Toler: 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 Taylor Beech at 202-551-4515 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Kenneth Koch, Esq.