Graubard Miller


The Chrysler Building

405 Lexington Avenue

New York, N.Y. 10174-1101

(212) 818-8800

facsimile   direct dial number
(212) 818-8881   (212) 818-8638
    email address

April 24, 2018




Mr. John Reynolds

Assistant Director

Office of Beverages, Apparel, and Mining

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549


Re: Bendon Group Holdings Limited
  Amendment No. 2 to Registration Statement on Form F-4
  Filed April 23, 2018
  File No.:  333-223786


Dear Mr. Reynolds:


As discussed with Jonathan Burr of the staff of the Securities and Exchange Commission (the “Staff”), attached are proposed edits to the above-captioned registration statement (the “Registration Statement”), which address the comment set forth in the Staff’s letter, dated as of today, relating to the Registration Statement. If you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.


  /s/ Jeffrey M. Gallant