TEMPUR SEALY INTERNATIONAL, INC.

1000 TEMPUR WAY

LEXINGTON, KENTUCKY 40511

March 4, 2016

BY EDGAR AND FACSIMILE

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn: Jay Ingram, Legal Branch Chief, Office of Manufacturing and Construction

 

Re:	Tempur Sealy International, Inc.

Registration

Statement on Form S-4 Filed February 12, 2016

File No.

333-209511

Ladies and Gentlemen:

Pursuant to Rule 461 of the rules and regulations under the Securities Act of 1933, as amended (the “Securities Act”), Tempur Sealy International, Inc. hereby requests acceleration of the effectiveness of the above-referenced Registration Statement on Form S-4 to 10:00 a.m. on Tuesday, March 8, 2016, or as soon thereafter as possible.

We confirm that we are aware of our responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the above-referenced Registration Statement.

We acknowledge that: (i) should the U.S. Securities and Exchange Commission (the “Commission”) or its staff (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve us from our full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) we may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please address any questions or comments with respect to this request to our counsel, Thompson & Knight LLP, by contacting Amy Curtis (telephone: (214) 969-1763; facsimile (214) 999-1564).

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Tempur Sealy International, Inc.

March 4, 2016

Page 2

Sincerely,

 

Tempur Sealy International, Inc.
By:		/s/ Barry A. Hytinen
		Name: Barry A. Hytinen
		Title: Executive Vice President and Chief Financial Officer
cc:		Lou H. Jones, Executive Vice President, General Counsel and Secretary
		Joe Dannenmaier, Thompson & Knight LLP