April 16, 2020

Russell Becker
Chief Executive Officer
APi Group Corporation
c/o APi Group, Inc.
1100 Old Highway 8 NW
New Brighton, MN 55112

       Re: APi Group Corporation
           Registration Statement on Form S-4
           Filed April 2, 2020
           File No. 333-237553

Dear Mr. Becker:

       We have reviewed your 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 amending your registration statement
and providing the
requested information. 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 any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Form S-4 filed April 2, 2020

APG Management's Discussion and Analysis of Financial Condition and Results of
Operations
Economic, Industry and Market Factors, page 46

1.     We note your disclosures of potential adverse impacts from COVID-19.
Please tell us
       what consideration you gave to providing expanded information regarding
specific
       impacts that your business has experienced from the COVID-19 pandemic
(e.g. number of
       cancelled projects, supplies that you cannot obtain). Refer to CF
Disclosure Guidance:
       Topic No. 9.
 Russell Becker
APi Group Corporation
April 16, 2020
Page 2
Combined Company, page 49

2.    We note your presentation of the combined results of operations of the
Successor and the
      Predecessor for the year ended December 31, 2019. Please tell us how you
determined it
      was appropriate to present these combined results without reflecting all
relevant pro forma
      adjustments required by Article 11 of Regulation S-X.
Notes to Consolidated Financial Statements
Note 13. Income Taxes, page F-41

3.    We note your reconciliation at the bottom of page F-42. Please clarify
for us the nature of
      the deferred remeasurement line item. Within your response, please tell
us your basis in
      U.S. GAAP for your accounting for this item.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Howard Efron at 202-551-3439 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Brigitte Lippmann at 202-551-3713 with
any other
questions.



                                                           Sincerely,
FirstName LastNameRussell Becker
                                                           Division of
Corporation Finance
Comapany NameAPi Group Corporation
                                                           Office of Real
Estate & Construction
April 16, 2020 Page 2
cc:       Donn A. Beloff Esq.
FirstName LastName