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                               February 1, 2023

       Lawrence I. Rosen
       Chairman
       Larose Industries LLC
       1578 Sussex Turnpike (Bldg. 5)
       Randolph, NJ 07869

                                                        Re: JAKKS Pacific, Inc.
                                                            Schedule 13D filed
by Lawrence I. Rosen
                                                            Filed January 26,
2023
                                                            File No. 005-50369

       Dear Lawrence I. Rosen:

                                                        We have reviewed the
above-captioned filing, and have the following comments.

               Please respond to this letter by amending the filing or by
providing the requested
       information. If a belief exists that our comments do not apply to your
facts and circumstances or
       that an amendment is inappropriate, please advise us why in a response
letter.

               After reviewing any amendment to the filing and any information
provided in response to
       these comments, we may have additional comments.

       Schedule 13D filed January 26, 2023

       General

   1.                                                   We note the date of the
event reported as requiring the filing of the Schedule 13D was
                                                        April 11, 2022. Rule
13d-1(a) of Regulation 13D-G requires the filing of a Schedule
                                                        13D within 10 days
after the acquisition of more than five percent of a class of equity
                                                        securities specified in
Rule 13d-1(i). Based on the reported April 11, 2022 event date, the
                                                        January 26, 2023 filing
was not timely filed. Please advise us why the Schedule 13D was
                                                        not filed within the
required 10 days after the acquisition.
   2.                                                   We note the disclosure
provided under Item 5(c) indicates that the appended Schedule A
                                                        provides a list of
transactions in the shares of common stock that were effected "during
                                                        the past 60 days." This
disclosure was consistent with the text of Item 5(c) of Schedule
                                                        13D, which requires
beneficial owners reporting on Schedule 13D to provide a description
                                                        of "any transactions in
the class of securities reported on that were effected during the past
                                                        sixty days...."
Notwithstanding the unqualified references to the "past 60 days" in the both
                                                        the regulatory text and
the corresponding narrative response to Item 5(c), the associated
 Lawrence I. Rosen
Larose Industries LLC
February 1, 2023
Page 2
         Schedule A only provided a transaction history within the past 60 days
of the date of the
         purported event that required reporting. Please provide us with a
legal analysis in support
         of your apparent conclusion that the disclosure in Schedule A complies
with Item 5(c).
         Alternatively, please amend the Schedule 13D to include a description
of transactions
         effected during the past 60 days of the filing date.
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.

       Please direct any questions to Michael Killoy at (202) 551-7576 or
Nicholas Panos at
(202) 551-3266.



FirstName LastNameLawrence I. Rosen                           Sincerely,
Comapany NameLarose Industries LLC
                                                              Division of
Corporation Finance
February 1, 2023 Page 2                                       Office of Mergers
& Acquisitions
FirstName LastName