United States securities and exchange commission logo

                             January 22, 2021

       William Toler
       Chief Executive Officer
       Hydrofarm Holdings Group, Inc.
       2249 South McDowell Boulevard Ext.
       Petaluma, California 94954

                                                        Re: Hydrofarm Holdings
Group, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted January
19, 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 Cara
Wirth at (202) 551-7127 with any questions.


                             Division of Corporation Finance

                             Office of Trade & Services
       cc:                                              Kenneth Koch