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July 20, 2021

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

Re: Cadre Holdings,
Inc.
Registration
Statement on Form S-1
Filed July 12, 2021
File No. 333-257849

Dear Mr. Kanders:

We have reviewed your registration statement and have the
following comment. In our
comment, 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 comment applies 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 the comment, we may have additional comments.

Form S-1 filed July 12, 2021

Dilution, page 32

1. Please explain how you
calculated the historical net tangible book value as of March 31,
2021 of $185,190,000 as
that appears to be your amount of total assets less goodwill and
intangible assets.
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.
Warren B. Kanders
Cadre Holdings, Inc.
July 20, 2021
Page 2

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
July 20, 2021 Page 2
cc: Robert L. Lawrence, Esq.
FirstName LastName