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                             September 23, 2021

       John Reed
       Chief Executive Officer
       Arhaus, Inc.
       51 E. Hines Hill Road
       Boston Heights, Ohio 44236

                                                        Re: Arhaus, Inc.
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted September
7, 2021
                                                            CIK No. 0001875444

       Dear Mr. Reed:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 1 to Draft Registration Statement on Form S-1

       Competitive Strengths
       Superior and Consistent Unit Economics, page 8

   1.                                                   Refer to your response
to prior comment 10. It does not appear the added definition of
                                                        "unit-level adjusted
EBITDA" on page iii states how the related margin is computed.
                                                        Please revise
   2.                                                   It appears
unit-level adjusted EBITDA    is a non-GAAP financial measure. Please
                                                        present the disclosure
required by Item 10(e) of Regulation S-K, including a reconciliation
                                                        to the most directly
comparable GAAP financial measure. In this regard, it appears the
 John Reed
Arhaus, Inc.LastNameJohn Reed
Comapany 23,
September   NameArhaus,
               2021      Inc.
Page 2     23, 2021 Page 2
FirstName LastName
         comparable GAAP measure is "income from operations" presented on your
statement of
         comprehensive income as it appears the non-GAAP measure is intended to
represent the
         direct operations of showrooms and is not indicative of overall
company performance and
         profitability. Further, since the non-GAP measure relates to
operations at a showroom
         level, please remove "EBITDA" from the description of the measure as
EBITDA suggests
         a measure that relates to company wide results. Refer to questions
103.01 and 103.02 of
         the staff   s "Non-GAAP Financial Measures" Compliance and Disclosure
         (C&DI) for guidance.
Management's Discussion and Analysis of Financial Condition and Results of
How We Assess the Performance of Our Business
Net Revenue and Demand, page 76

3.       From your disclosures and responses it appears    demand merchandise
revenue    and
            merchandise revenue    are equivalent as they both represent retail
sales of merchandise.
         You state in prior comment 3 returned merchandise is reflected in
demand    as an offset
         against retail sales. However, it is not clear how measures based on
         merchandise revenue    is reflective of this since    merchandise
revenue    as computed on
         page 77 excludes reserves for returns and discounts. Please advise.
Also, tell us how you
         determined that adding back to net revenue reserves related to returns
and discounts does
         not substitute individually tailored revenue recognition and
measurement methods for
         those of GAAP as it appears these enter into the determination of the
merchandise retail
         sale amount. Refer to the answer to Question 100.04 of the above noted
4.       You add back    private label credit card fees and rebates    and
worry free warranty fees
         as adjustments in calculating the "merchandise revenue" measure.
Please explain to us
         and expand your disclosure to discuss the nature of these adjustments
and your basis for
         including such amounts in "merchandise revenue."
Adjusted EBITDA, page 78

5.       You disclose your "adjusted EBITDA" non-GAAP measure omits items that
are not
         reflective of underlying operating performance. Please clarify why you
do not consider
         the new showroom opening expenses to be normal, recurring, cash
operating expenses
         necessary to operate your business when these costs have been incurred
every quarter
         since March, 2019, showrooms appear to be integral to your operations
and you plan to
         continue to increase your number of showrooms for the foreseeable
future. Refer to
         Question 100.01 of the staff   s Non-GAAP Financial Measures
Compliance and Disclosure
Statement of Consolidated Comprehensive Income Data, page 80

6.       Please present with equal or greater prominence the GAAP measure
comparable to the
         non-GAAP measure "adjusted EBITDA as a % of net revenue." Refer to
         10(e)(1)(i)(A) of Regulation S-K.
 John Reed
Arhaus, Inc.
September 23, 2021
Page 3
Comparison of the Six Months Ended June 30, 2021 and June 30, 2020
Gross Margin, page 81

7.       Please expand your discussion to explain the causes of the greater
than 10% increase in
         gross margin as a percentage of net revenue in the six months ended
June 30, 2021 as
         compared to the percentage in the six months ended June 30, 2020 and
the relative
         contribution of each cause to the increase. Consider similar analysis
for the annual period
         as there is a greater than 10% increase in that period's gross margin
percentage as well.
Results of Operations
Comparison of the Years Ended December 31, 2020 and December 31, 2019, page 82

8.       Refer to your response to prior comment 21. From your disclosure under
"Gross margin"
         the aggregate of lower costs of $5.2 million attributable to strategic
sourcing and lower
         costs as a result of temporary showroom closings was partially offset
by higher credit card
         fees of $4.0 million. This does not materially explain the $10.6
million decrease in cost of
         goods sold or the reason for the inverse relationship it has with
revenue when a direct
         relationship is expected. Please expand your disclosure as appropriate
following the
         guidance in Item 303(a), (b) and (b)(2)(i) and (ii) of Regulation S-K
and section III of
         Release No. 33-8350. Given the materiality of cost of goods sold to
your results of
         operations, consider discussing material changes in cost of goods sold
in a separate
         section for greater transparency to investors. Please consider the
preceding in regard to
         the change in cost of goods sold for the interim period as the gross
margin analysis for that
         period appears to only explain $15.0 million of the approximately
$68.0 million change in
         cost of goods sold for the period.
Liquidity and Capital Resources
Net cash provided by operating activities, page 85

9.     Refer to your response to prior comment 22 and disclosure of the changes
in net cash
       provided by operating activities for both the interim and annual
periods. It appears
       operating cash is not impacted by the non-cash items referred to. Also,
there is no
       discussion of the underlying factors affecting changes in working
capital and the
FirstName LastNameJohn Reed
       consequent impact on cash. Please revise your disclosure as appropriate
following the
Comapany   NameArhaus,
       guidance            Inc.
                 in the introductory paragraph of section IV.B and paragraph
B.1 of SEC Release
       No. 23,
September  33-8350.
               2021 Page 3
FirstName LastName
 John Reed
Arhaus, Inc.LastNameJohn Reed
Comapany 23,
September   NameArhaus,
               2021      Inc.
Page 4     23, 2021 Page 4
FirstName LastName
       You may contact Suying Li at 202-551-3335 or Doug Jones at 202-551-3309
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Donald Field at 202-551-3680 or Lilyanna Peyser at 202-551-3222 with any other


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