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December 23, 2019

U.S. Securities and Exchange Commission,

Division of Corporation Finance,

100 F Street, N.E.,

Washington, D.C. 20549.


Attn:		Ernest Greene
		Sherry Haywood
		Anne McConnell
		Asia Timmons-Pierce

Re:		CPG Newco LLC
		Amendment No. 5 to Draft Registration Statement on Form S-1
		Submitted December 23, 2019
		CIK No. 1782754

Dear Ladies and Gentlemen:

On behalf of our client, CPG Newco LLC (the “Company”), enclosed herewith are a clean copy of the Company’s Amendment No. 5 to the Confidential Draft Registration Statement on Form S-1 (the “Draft Registration Statement”) submitted to the Securities and Exchange Commission on December 23, 2019 and a version that is marked to show changes from the Company’s Amendment No. 4 to the Draft Registration Statement submitted on November 12, 2019. Please note that the Company has determined not to enter into a tax receivable agreement in connection with its initial public offering, and all references to the tax receivable agreement have been removed from the Draft Registration Statement.

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Very truly yours,

		/s/ John L. Savva
		John L. Savva