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milbank.com

July 22, 2024

VIA EDGAR

United States Securities and Exchange Commission

100 F Street, N.W.

Washington, D.C. 20549

Attn: Beverly Singleton or Andrew Blume

Re: Turning Point Brands, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2023

Form 8-K Filed May 2, 2024

File No. 001-37763

Dear Ms. Singleton and Mr. Blume:

This letter confirms that Turning Point Brands, Inc. (the “Company”) has received your letter, dated July 9, 2024 (the “Letter”), and as discussed with Mr. Andrew Blume, the Company intends to respond to the Letter on or before July 31, 2024.

Please don’t hesitate to contact Brett D. Nadritch of Milbank LLP at (212)-530-5301 with any questions.

Sincerely,

/s/ Brett D. Nadritch

Brett D. Nadritch

CC: Andrew Flynn, Chief Financial Officer

Brittani N. Cushman, General Counsel and Corporate Secretary

Brian Wigginton, Chief Accounting Officer