United States securities and exchange commission logo February 11, 2022 Ira Schlussel Vice President, General Counsel & Secretary Whole Earth Brands, Inc. 125 S. Wacker Drive, Suite 3150 Chicago, IL 60606 Re: Whole Earth Brands, Inc. Registration Statement on Form S-3 Filed February 4, 2022 File No. 333-262535 Dear Mr. Schlussel: 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 Gregory Herbers at 202-551-8028 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Christopher Giordano