Callaway Golf Company
2180 Rutherford Road
Carlsbad, California 92008
January 26, 2021
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
| Re: | Callaway Golf Company |
Registration Statement on Form S-4
File No. 333-250903
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, Callaway Golf Company (the “Registrant”) hereby requests acceleration of the effective date of the Registration Statement on Form S-4 (File No. 333-250903), as amended (the “Registration Statement”), so that it may become effective at 4:00 p.m. Eastern Time on January 27, 2021, or as soon as possible thereafter. The Registrant hereby authorizes Craig M. Garner and/or Kevin C. Reyes, of Latham & Watkins LLP, to orally modify or withdraw this request for acceleration.
Thank you for your assistance. We request that we be notified of such effectiveness by a telephone call to Mr. Reyes at (858) 523-3946, or in his absence Mr. Garner, of Latham & Watkins LLP, at (858) 523-5407. We also respectfully request that a copy of the written order from the Commission verifying the effective time and date of such Registration Statement be sent to Mr. Reyes via email to kevin.reyes@lw.com or via facsimile to Latham & Watkins LLP, attention: Kevin C. Reyes, via facsimile at (858) 523-5450.
| Very truly yours, |
| Callaway Golf Company |
| /s/ Brian P. Lynch |
| Brian P. Lynch |
| Executive Vice President, Chief Financial Officer |
| cc: | William Davenport, Topgolf International, Inc. |
Craig M. Garner, Latham & Watkins LLP
Kevin C. Reyes, Latham & Watkins LLP
James R. Griffin, Weil, Gotshal & Manges LLP
David B. Gail, Weil, Gotshal & Manges LLP
Kevin J. Sullivan, Weil, Gotshal & Manges LLP