United States securities and exchange commission logo





                              March 23, 2022

       Andrew Freedman
       Olshan From Wolosky LLP
       1325 Avenue of the Americas
       New York, NY
       10019

                                                        Re: Turtle Beach Corp
                                                            Soliciting
Materials filed pursuant to Rule 14a-12
                                                            Filed by The
Donerail Group LP, The Donerail Master Fund LP, William
                                                            Wyatt, Harbert
Donerail Fund GP LLC, Donerail Group GP LLC,
                                                            Harbert Fund
Advisors, Inc., Harbert Management Corporation, SCW
                                                            Capital, LP, SCW
Capital QP, LP, SCW Capital Management, LP,
                                                            Trinity Investment
Group, LLC, Robert Cathey, Terry Jimenez, Kimberly
                                                            Kreuzberger,
Katherine L. Scherping, Brian Stech, and Michelle D. Wilson
                                                            File No. 001-35465

       Dear Mr. Freedman:

              We have reviewed your filing 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 these comments by providing the requested
information or advise us as
       soon as possible when you will respond. If you do not believe our
comments apply to your facts
       and circumstances, please tell us why in your response.

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

       Soliciting Materials filed pursuant to Rule 14a-12

       Soliciting Materials, page 1

   1.                                                   You must avoid issuing
statements that directly or indirectly impugn the character,
                                                        integrity or personal
reputation or make charges of illegal, improper or immoral conduct
                                                        without factual
foundation. Provide us supplementally, or disclose, the factual foundation
                                                        for the statement
referring to the "the Board's willful ignorance of its fiduciary
                                                        obligations..." In this
regard, note that the factual foundation for such assertion must be
                                                        reasonable. Refer to
Rule 14a-9.
 Andrew Freedman
1325 Avenue of the Americas
March 23, 2022
Page 2
2.       Each statement or assertion of opinion or belief must be clearly
characterized as such, and
         a reasonable factual basis must exist for each such opinion or belief.
Support for opinions
         or beliefs should be self-evident, disclosed in the proxy statement or
provided to the staff
         on a supplemental basis. Accordingly, please provide your basis for
the following:

                your skepticism about "management's ability to change the
Company's downward
              trajectory."
                your disclosure about "interactions with other shareholders,
who also seem to have
              lost all confidence in the Company's leadership."

        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

         Please direct any questions to Daniel Duchovny at 202-551-3619.



FirstName LastNameAndrew Freedman                              Sincerely,
Comapany Name1325 Avenue of the Americas
                                                               Division of
Corporation Finance
March 23, 2022 Page 2                                          Office of
Mergers & Acquisitions
FirstName LastName