United States securities and exchange commission logo March 23, 2023 Haitham Khouri Chief Executive Officer Perimeter Solutions, SA 12E rue Guillaume Kroll, L-1882 Luxembourg Grand Duchy of Luxembourg 352 2668 62-1 Re: Perimeter Solutions, SA Registration Statement on Form S-3 Filed March 15, 2023 File No. 333-270579 Dear Haitham Khouri: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Jordan Nimitz at 202-551-5831 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services