Suzanne K. Hanselman

direct dial: 216.861.7090

SHanselman@bakerlaw.com

Arhaus, Inc., Registration Statement on Form S-1, Filed October 4, 2021, File No. 333-260015

Here or in another appropriate place, please identify the natural persons who having voting and dispositive control over the Freeman Spogli Funds.

Please revise to clarify what “New Showroom contribution” and “New Showroom Revenue” represent. For “New Showroom contribution,” discuss what the measure consists of. For “New Showroom revenue,” discuss how this amount is determined.

We note your response to comment 3 that asserts “demand” and “merchandise revenue include actual returns as offsets in the applicable period. You revised the definition of “merchandise revenue” on page iii to state this. However, the definition of “demand” on page iv does not state this. Please revise the definition of “demand” accordingly.

Please explain to us and disclose as appropriate how amounts for “demand” and “merchandise revenue” include actual returns as offsets in the applicable period.

As disclosed, “demand” is retail sales of merchandise measured at the time the order is placed and “merchandise revenue” is retail sales of merchandise from orders when delivered. Please clarify for us and in your disclosures if the amount for “demand” differs from the amount for “merchandise revenue” other than the point of time each is measured. Also, explain for us and disclose as appropriate how the amount for demand becomes merchandise revenue. If the amount for demand is not the same as the amount for merchandise revenue, tell us and disclose as appropriate the percentage of demand that becomes merchandise revenue.

In the comparisons for the interim and annual periods, for balance please include with equal or greater prominence GAAP “net income as a percent of net revenue” that is comparable to the non-GAAP “adjusted EBITDA as a percent of net revenue” presented.

Please delete as inappropriate your statement that your actual results may differ “materially” from the preliminary results that you have provided. In addition, include your analysis of the financial measures, so that investors can understand what they mean (for example, whether the measures are consistent with the trend disclosure in your Management’s Discussion and Analysis section). Finally, please balance the existing disclosure with other disclosure relating to costs or gross margin.

Please revise your capitalization table to only give effect to the Reorganization and Distribution transactions in the pro forma column. Please present a separate pro forma as adjusted column to reflect the pro forma capitalization after giving effect to the offering, including the repayment of your term loan with the offering proceeds.

In regard to both “New Showroom contribution” and “New Showroom revenue” non- GAAP measures on page 82, you exclude the operating performance for the showrooms that were opened before January 1, 2016 and after December 31, 2018. Please clarify for us and in your disclosure what a new showroom is considered to be and the reasoning for excluding showrooms opened after December 31, 2018 from the new showroom category. Also, explain to us the reason for the gap between the noted dates. Additionally, expand your disclosure to explain how management uses these measures and why you believe they provide useful information to investors regarding your performance pursuant to Item 10(e)(1)(i)(C) and (D) of Regulation S-K.

You state you exclude general and administrative expense in computing “New Showroom Contribution” because they are not directly attributable to a Showroom’s economic performance and include the other indicated costs. However, it appears these expenses are essential to support the operation and development of your showrooms. Please revise your disclosure to explain the limitations on the usefulness of this measure in that it is not indicative of overall results of the company, it does not accrue directly to the benefit of shareholders because of the costs excluded and the excluded costs support the operations of your showrooms.

Please explain to us and revise to disclose what “Other Showroom and eCommerce Contribution” represents and how it is determined. Additionally, it appears this is a non- GAAP measure. Accordingly, comply with the requirements of Item 10(e)(1)(i) of Regulation S-K, including reconciliation to the comparable GAAP measure.

Please explain to us and revise to disclose what “Other Showroom and eCommerce net Revenue” represents and how it is determined.

We note that the company and certain stockholders are party to an investor rights agreement which includes certain provisions regarding the election of directors. Please revise this section to clarify if there are any arrangements or understandings between any director and any other person or persons pursuant to which such director was or is to be selected as a director or director nominee. Refer to Item 401(a) of Regulation S-K.