February 10, 2020

Mark W. Miles
Chief Financial Officer
Berry Global Group, Inc.
101 Oakley Street
Evansville, Indiana 47710

       Re: Berry Global Group, Inc.
           Form 10-K for the Fiscal Year Ended September 28, 2019
           Filed November 22, 2019
           File No. 001-35672

Dear Mr. Miles:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended September 28, 2019

Consolidated Financial Statements
Note 2. Acquisitions and Dispositions, page 41

1.    Refer to your disclosures regarding the RPC acquisition. Please expand to
disclose the
      amount of net sales and income of RPC since the acquisition date included
in your
      statements of income for fiscal year ended September 28, 2019. Refer to
ASC 805-10-
      50-2h(1). Please disclose the nature and amount of any material,
nonrecurring pro forma
      adjustments directly attributable to the acquisition included in the pro
forma net sales and
      income amounts. Refer to ASC 805-10-50-2h(4). Also, please reconcile the
$70 million
      of costs associated with the closing of the transaction with the $130
million amount
      disclosed in MD&A on page 13. Further, we note your narrative disclosures
of the assets
      acquired and liabilities assumed in the second paragraph. Given the
significance of this
      acquisition, please consider providing in a tabular reconciliation of the
preliminary
      purchase price allocation and consideration paid using the guidance of
ASC 805-20-50-
 Mark W. Miles
Berry Global Group, Inc.
February 10, 2020
Page 2
         1(c) and ASC 805-10-55-41.

       In closing, 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.

      You may contact Beverly Singleton at (202) 551-3328 or John Cash at (202)
551-
3768 with any questions.



FirstName LastNameMark W. Miles                           Sincerely,
Comapany NameBerry Global Group, Inc.
                                                          Division of
Corporation Finance
February 10, 2020 Page 2                                  Office of
Manufacturing
FirstName LastName