Park National Corporation

50 North Third Street

Newark, Ohio 43058

(740) 349-8451

November 15, 2018

VIA EDGAR

Eric Envall

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Park National Corporation Registration Statement on Form S-4; File No. 333-228145 Request for Acceleration

Dear Mr. Envall:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Park National Corporation (the “Company”) hereby requests that its Registration Statement on Form S-4 filed with the Securities and Exchange Commission (the “Commission”) on November 2, 2018 (File No. 333-228145), as amended on November 15, 2018 (the “Registration Statement”), be made effective at 4:00 p.m. (EST) on November 19, 2018, or as soon as possible thereafter.

Please contact James J. Barresi of Squire Patton Boggs (US) LLP at (513) 361-1260 or by email at james.barresi@squirepb.com with any questions you may have concerning this request.  In addition, please notify Mr. Barresi when this request for acceleration has been granted.

PARK NATIONAL CORPORATION
By:	/s/ David L. Trautman
	David L. Trautman
	Chief Executive Officer and President

cc: James J. Barresi, Squire Patton Boggs (US) LLP