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June 29, 2021

Warren B. Kanders
Chief Executive Officer
Cadre Holdings, Inc.
13386 International Pkwy
Jacksonville, FL 32218

Re: Cadre Holdings,
Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted June 15,
2021
CIK No. 0001860543

Dear Mr. Kanders:

We have reviewed your amended 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.

Amendment No. 1 to Draft Registration Statement on Form S-1

Prospectus Summary
Competitive Strengths, page 3

1. We note your response
to prior comment 1. Please expand your disclosure here and on
page 54 to describe
your market position across relevant product categories based on the
data and information
you rely upon.
Risks Related to Our Business, page 5

2. We note your response
to prior comment 2. Please revise the bullet at the bottom of page
5 to provide the
anticipated beneficial ownership of Mr. Kanders.
Warren B. Kanders
Cadre Holdings, Inc.
June 29, 2021
Page 2
Risk Factors
Risks Related to Our Business
We may lose money or generate less than expected profits on our fixed-price
contracts, page 16

3. We note your response to prior comment 3. Please expand your disclosure
to identify the
estimated percentage of the net sales from your Distribution segment that
is represented
by fixed-price contracts.
Business
Intellectual Property and Trademarks, page 60

4. We note your response to prior comment 14, which we reissue in part.
Please revise your
disclosure to describe your patent portfolio by product category,
included the related
expiry. Please segregate your issued patents and pending patent
applications. Please
consider tabular disclosure in addition to the narrative provided.
Additionally, please
revise to disclose whether the loss of patent protection for patents
expiring in 2021 is
expected to have a material effect on your business.
Legal Proceedings, page 61

5. We note your response to prior comment 13. Please revise to provide the
disclosure
related to the FTC and DOJ actions under the Legal Proceedings heading.
Certain Relationships and Related Party Transactions, page 75

6. We note your response to prior comment 16. Please revise to clarify
whether Mr. Kanders
was involved in your decisions to engage Kanders & Company with respect
to either of
the transactions described and, if so, describe the nature of his
involvement. Additionally,
please disclose whether a committee of your independent directors
approved or reviewed
the transactions with Kanders & Company.
You may contact Jeanne Bennett at 202-551-3606 or Lynn Dicker at
202-551-3616 if you
have questions regarding comments on the financial statements and related
matters. Please
contact David Gessert at 202-551-2326 or Christine Westbrook at 202-551-5019
with any other
questions.



Sincerely,
FirstName LastNameWarren B. Kanders
Division of
Corporation Finance
Comapany NameCadre Holdings, Inc.
Office of Life
Sciences
June 29, 2021 Page 2
cc: Robert L. Lawrence, Esq.
FirstName LastName