ck0001746618-corresp.htm

Los Angeles, CA 90071-2027

PHONE 323.210.2900

FAX 866.974.7329

www.wsgr.com

Attention:		Mara L. Ransom
		Ta Tanisha Meadows
		Bill Thompson
		Danilo Castelli
		Jennifer López-Molina

	Re:	Advance Holdings, LLC
		Revolve Group, Inc.
		Draft Registration Statement on Form S-1
		Submitted September 19, 2018
		CIK No. 0001746618

On behalf of our client, Advance Holdings, LLC (the “Company”), we submit this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated September 27, 2018, relating to the above referenced Confidential Draft Registration Statement on Form S-1. On behalf of the Company, we are concurrently filing via EDGAR a Registration Statement (the “Registration Statement”), and for the convenience of the Staff, we are providing to the Staff by overnight delivery copies of this letter and marked copies of the Registration Statement (against the September 19, 2018 confidential submission).

In this letter, we have recited the comments from the Staff in italicized, bold type and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below, all page references herein correspond to the page of the Registration Statement, as applicable.

Management’s Discussion and Analysis of Financial Condition and Results of Operation

Your disclosure states that media impressions consider the “number of followers of the social media account or viewership or readership.” If you consider followers solely because such followers have access to the specific social media post or feature that mentions your company or brands, please revise to characterize in terms of potential, rather than assured, reach. In doing so, tell us how you are able to measure the reach of blogs, on-line and print magazines.

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In response to the Staff’s comment, the Company has deleted references to media impressions from the Registration Statement.

As a related matter, please balance your disclosure by quantifying what portion of your media impressions are derived from paid vs. free sources. In this regard, we note your disclosure that 54% of traffic to your site is derived from “free or low-cost” sources, such as “email marketing links, or through paid branded search terms and organic search results.” However, you do not provide a similar breakdown for the “followers of the social media account or viewership or readership” referenced in your definition of “media impressions,” so that readers can appreciate the extent of your influence over the volume of impressions that you disclose.

In response to the Staff’s comment, the Company has deleted references to media impressions from the Registration Statement.

We note that during the 12 months ended June 30, 2018, you generated, on average, 8.4 million unique visitors per month, “reflecting increasing appeal of [your] site.” Please define the term “unique visitor” and disclose the average unique visitors during the same period last year to contextualize the increase in appeal of your website.

In response to the Staff’s comment, the Company has revised the disclosure on pages 5 and 90.

Please direct any questions regarding the Company’s responses or the revised draft of the Registration Statement to me at (206) 883-2524 or mnordtvedt@wsgr.com.

cc:	Jesse Timmermans, Advance Holdings, LLC
	Katherine Ku, Wilson Sonsini Goodrich & Rosati P.C.
	Tom Holden, Ropes & Gray LLP
	Jeff Rawlins, KPMG LLP