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                           January 14, 2021

       Sean Sullivan
       Executive Vice President
       Mallard Intermediate, Inc.
       1201 Dowdell Lane
       Saint Helena, CA 94574

                                                        Re: Mallard
Intermediate, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Filed December 18,
2020
                                                            CIK No. 1835256

       Dear Mr. Sullivan:

              We have reviewed your 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.

       DRS filed December 18, 2020

       Prospectus summary, page 1

   1.                                                   Please revise to ensure
that the information you include in your summary is balanced,
                                                        such as, by way of
example and not limitation, more prominent disclosure of the amount
                                                        of your indebtedness.
To the extent that you cite strengths in your summary, please
                                                        review each one and
revise as necessary to provide balanced information, rather than
                                                        merely listing
generalized risk factors at the end of this section.
 Sean Sullivan
FirstName  LastNameSean
Mallard Intermediate, Inc. Sullivan
Comapany
January 14,NameMallard
            2021          Intermediate, Inc.
January
Page 2 14, 2021 Page 2
FirstName LastName
Management's discussion and analysis of financial condition and results of
operations
Key financial metrics, page 64

2.       We note you present Adjusted EBITDA as a key financial metric without
reference to Net
         Income. Please present the most directly comparable GAAP measure with
equal or greater
         prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and
Question 102.10 of the
         staff  s Compliance and Disclosure Interpretation on Non-GAAP
Financial Measures
         ("C&DI  s").
Liquidity and capital resources
Operating activities, page 77

3.       Your disclosure indicates that cash flows from operating activities
were impacted by
         changes in operating assets and liabilities. Please expand your
disclosure to include a
         robust discussion describing and quantifying the specific effects of
the drivers that
         contributed to the material changes in your operating cash flows for
the periods presented.
         The disclosure should also include a discussion of the underlying
reasons for changes
         in working capital items that affect operating cash flows. We further
note that your trade
         receivables balance increased at a significantly higher rate than
sales in the quarter ended
         October 31, 2020 and more negatively impacted operating cash flows.
Please discuss the
         underlying reasons for material changes in trade receivables and the
impact such changes
         have on your cash flows, including a discussion of financial measures
such
         as days sales outstanding that would be relevant to a reader of your
financial statements
         given the negative trend in this metric during recent periods. See
section IV.B of the SEC
         Interpretive Release No. 33-8350.
Credit facility, page 78

4.       We note that the interest rate of your credit facility is tied to
LIBOR. Please provide risk
         factor disclosure related to the impact of the discontinuation of
LIBOR on your credit
         facility. Alternatively, please tell us why you believe you are not
required to do so.
Critical accounting policies and estimates
Goodwill and intangible assets, page 81

5.       We note that you performed a quantitative assessment of your goodwill
in fiscal 2020 and
         determined that goodwill was not impaired. To the extent your
reporting unit is at risk of
         failing step one of the goodwill impairment test, disclose the
percentage by which the fair
         value exceeded the carrying value as of the date of the most recent
test and describe any
         potential events and/or changes in circumstances, such as the recent
pandemic, that could
         reasonably be expected to negatively affect any key assumptions. If
you have determined
         that the estimated fair value substantially exceeds the carrying value
of your reporting
         unit, please disclose such determination. Refer to Section V of SEC
Release 33-8350.
6.       We note you recorded an $11.8 million impairment charge related to
certain trade names
 Sean Sullivan
Mallard Intermediate, Inc.
January 14, 2021
Page 3
      as a result of your June 30, 2020 impairment testing. Please explain how
you determined
      the significant assumptions you used in the relief from royalty
calculations to estimate the
      fair value of the trade names and provide a sensitivity analysis that
demonstrates the
      potential impact of changes in such assumptions.
Agreements with our named executive officers, page 116

7.    Please file your employment agreements with your named executive officers
and include
      the agreements in your exhibits index.
Director compensation, page 118

8.    We note your disclosure in footnote (2) to the table. For each director,
please disclose the
      name of the investor that is affiliated with such director and any
arrangements with such
      investor.
Services Agreement, page 121

9.    Please discuss the material terms of the services agreement and file the
agreement as an
      exhibit to the registration statement. Refer to Item 601(b)(1) of
Regulation S-K.
8. Debt, page F-22

10.   Please file as exhibits to your registration statement copies of your
material
      credit agreements, or tell us why you believe you are not required to do
so. Refer to Item
      601(b)(10) of Regulation S-K.
Notes to the Consolidated Financial Statements
13. Commitments and Contingencies
Contingent Liabilities, page F-31

11.   We assume you accrue liabilities related to contingencies when they are
 probable    and
         reasonably estimable    as required by ASC 450-20-25-2. Please revise
your disclosure
      accordingly.
        You may contact Mindy Hooker, Staff Accountant at (202) 551-3732 or
John Cash,
Accounting Branch Chief at (202) 551-3768 if you have questions regarding
comments on the
financial statements and related matters. Please contact Sherry Haywood, Staff
Attorney at (202)
551-3345 or Asia Timmons-Pierce, Special Counsel at (202) 551-3754 with any
other questions.



                                                            Sincerely,
FirstName LastNameSean Sullivan
Comapany NameMallard Intermediate, Inc.                     Division of
Corporation Finance
January 14, 2021 Page 3                                     Office of
Manufacturing
cc:
FirstName Thomas Holden
          LastName