October 31, 2019

Ralph Nicoletti
Senior Vice President and Chief Financial Officer
CPG Newco LLC
1330 W. Fulton Street #350
Chicago, IL 60607

       Re: CPG Newco LLC
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Filed October 17, 2019
           CIK No. 1782754

Dear Mr. Nicoletti:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 2 to Draft Registration Statement on Form S-1

Selected Consolidated Financial Data
Non-GAAP Financial Measures, page 65

1.     We note your response to comment three in our letter dated October 8,
2019. Please more
       fully address the following:
         It remains unclear to us why changes in your warranty policy would be
considered a
            non-recurring cost since warranty accruals are adjusted on an
ongoing basis based on
            historical experience;
         On page F-37, you disclose that you recorded a class action settlement
related to
            certain legacy products and their performance of $7.5 million and
paid $5.6 million to
            settle this class action. After the settlement, you indicate the
remaining balance of
 Ralph Nicoletti
CPG Newco LLC
October 31, 2019
Page 2
              $1.9 million was reversed in fiscal 2018. It remains unclear to
us what consideration
              you gave to adjusting your Non-GAAP financial measure for this
item which
              positively impacted your operating results based on your
adjustment for the related
              expense; and
              It remains unclear to us why you believe the tax impact of the
adjustments you
              present for fiscal 2018 is reasonable. In this regard, absent the
impact of the U.S. tax
              reform act, we do not understand why a tax rate of 3.8% is
reasonable. Based on the
              loss you recorded in fiscal 2018, it does not appear to us that
your use of this
              calculated effective tax rate is reasonable.


        You may contact Ernest Greene at (202) 551-3733 or Anne McConnell at
(202) 551-3709
if you have questions regarding comments on the financial statements and
related
matters. Please contact Sherry Haywood at (202) 551-3345 or Asia Timmons-Pierce
at (202)
551-3754 with any other questions.



FirstName LastNameRalph Nicoletti                               Sincerely,
Comapany NameCPG Newco LLC
                                                                Division of
Corporation Finance
October 31, 2019 Page 2                                         Office of
Manufacturing
FirstName LastName