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                                                            August 23, 2024

John Garilli
Trustee
LUB Liquidating Trust
Two Liberty Square, 9th Floor
Boston MA 02109

        Re: LUB Liquidating Trust
            Form 10-K
            Filed March 22, 2024
            File No. 001-08308
Dear John Garilli:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K filed March 22, 2024
General

1.      The consolidated financial statements presented in your Form 10-Ks for
fiscal years ended
        December 31, 2023 and 2022 and the Form 10-KT for period ending May 31,
2022 are
        unaudited. In addition, you have not filed a report on Form 10-Q since
the quarterly
        period ended March 9, 2022. Please advise us of your basis for not
providing audited
        financial statements and accompanying audit reports and not filing
reports on Form 10-Q
        since the noted period ended.
 August 23, 2024
Page 2

       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.

       Please contact Patrick Kuhn at 202-551-3308 or Doug Jones at
202-551-3309 with any
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services