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Correspondence 0001104659-26-046168 from CECO ENVIRONMENTAL CORP (CECO)

CECO ENVIRONMENTAL CORP
Date: April 21, 2026 · CIK: 0000003197 · Accession: 0001104659-26-046168

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File numbers found in text: 333-294924

Date
April 21, 2026
Author
/s/ Alyson Gregory
Form
CORRESP
Company
CECO ENVIRONMENTAL CORP

Letter

VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Energy & Transportation Washington, D.C. 20549-3561 Re: CECO Environmental Corp. Registration Statement on Form S-4, as amended File No. 333-294924

Dear Mr. Crispino:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), CECO Environmental Corp. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m., Eastern Time, on April 22, 2026, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Gibson, Dunn & Crutcher LLP, requests by telephone that such Registration Statement be declared effective. In making this acceleration request, the Company acknowledges that it is aware of its obligations under the Act.

Please contact Jonathan Whalen of Gibson, Dunn & Crutcher LLP by telephone at (214) 698-3196 or via email at JWhalen@gibsondunn.com as soon as the Registration Statement has been declared effective, or if you have any other questions regarding this matter. We also respectfully request that a copy of the written order from the Commission verifying the effective time of such Registration Statement be sent to Mr. Whalen via email at JWhalen@gibsondunn.com.

Sincerely,
CECO Environmental Corp.

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CORRESP
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CECO Environmental Corp.

5080 Spectrum Drive, Suite 800E

Addison, Texas 75001

April 21, 2026

VIA EDGAR

Matthew Crispino

Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, NE

Washington, D.C. 20549-3561

Re:          CECO Environmental Corp.

Registration Statement on Form S-4, as
amended

File No. 333-294924

Dear Mr. Crispino:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Act”), CECO Environmental Corp. (the “Company”) hereby requests
acceleration of the effective date of the above-referenced Registration Statement to 4:00 p.m., Eastern Time, on April 22, 2026, or as
soon thereafter as practicable, or at such other time as the Company or its outside counsel, Gibson, Dunn & Crutcher LLP, requests
by telephone that such Registration Statement be declared effective. In making this acceleration request, the Company acknowledges that
it is aware of its obligations under the Act.

Please contact Jonathan Whalen of Gibson, Dunn
& Crutcher LLP by telephone at (214) 698-3196 or via email at JWhalen@gibsondunn.com as soon as the Registration Statement has been
declared effective, or if you have any other questions regarding this matter. We also respectfully request that a copy of the written
order from the Commission verifying the effective time of such Registration Statement be sent to Mr. Whalen via email at JWhalen@gibsondunn.com.

    Sincerely,

    CECO Environmental Corp.

    /s/ Alyson Gregory

    Alyson Gregory

    General Counsel and Corporate Secretary

cc:       Jonathan Whalen, Gibson, Dunn &
Crutcher LLP