Form: UPLOAD

SEC-generated letter

September 27, 2021

Published on September 27, 2021

United States securities and exchange commission logo





September 27, 2021

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

Re: Cadre Holdings,
Inc.
Amendment No. 3 to
Registration Statement on Form S-1
Filed September 13,
2021
File No. 333-257849

Dear Mr. Kanders:

We have reviewed your amended 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 amending your registration
statement and providing the
requested information. 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 any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Unless we note
otherwise, our references to prior comments are to comments in our
[Month day, year] letter.

Amendment No. 3 to Registration Statement on Form S-1

Prospectus Summary
New Credit Agreement, page 6

1. Please revise to
disclose the amount outstanding under the revolving credit facility, if any,
as of a recent date.
Business
Legal Proceedings, page 65

2. We note your disclosure
on page 66 regarding the $7.5 million jury verdict awarded
against your
wholly-owned subsidiary, Safariland, LLC. Please expand your disclosure to
identify the plaintiff,
the court in which the proceedings are pending, the date instituted
Warren B. Kanders
Cadre Holdings, Inc.
September 27, 2021
Page 2
and a description of the factual basis alleged to underlie the
proceedings. See Item 103 of
Regulation S-K for guidance.
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
September 27, 2021 Page 2
cc: Robert L. Lawrence, Esq.
FirstName LastName