United States securities and exchange commission logo May 26, 2022 Douglas Cahill Chief Executive Officer Hillman Solutions Corp. 10590 Hamilton Avenue Cincinnati, Ohio 45231 Re: Hillman Solutions Corp. Form 10-K for the Fiscal Year Ended December 25, 2021 Filed March 16, 2022 File No. 001-39609 Dear Mr. Cahill: We have limited our review of your filing to the financial statements and related disclosures 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 25, 2021 Item 7 - Management's Discussion and Analysis of Financial Condition and Results of Operations Year Ended December 25, 2021 vs December 26, 2020 Net Sales, page 25 1. Please be advised should your income statements present material changes from period to period in net sales or revenues, you are required to describe (i.e. quantify) the extent the changes are attributed to changes in volume sold versus changes in prices. Refer to Item 303(b)(2)(iii) of Regulation S-K. Critical Accounting Policies and Estimates Inventory Realization, page 39 2. You disclose that inventories are valued at the lower of cost or net realizable value, cost Douglas Cahill Hillman Solutions Corp. May 26, 2022 Page 2 being determined principally on the standard cost method. Under ASC 330-10-30-12, standard costs are acceptable if adjusted at reasonable intervals to reflect current conditions so that at the balance sheet date standard costs reasonably approximate costs computed under one of the recognized bases. In future filings, please revise your disclosure here and on page 51 to state which of the recognized bases you use. Please also refer to ASC 330-10-30-9 for guidance. In closing, 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. You may contact Dale Welcome at 202-551-3865 or Jean Yu at 202-551-3305 with any questions. FirstName LastNameDouglas Cahill Sincerely, Comapany NameHillman Solutions Corp. Division of Corporation Finance May 26, 2022 Page 2 Office of Manufacturing FirstName LastName