SecProbe.io

January 24, 2013

Via Facsimile
Mr. James S. Porter
Chief Financial Officer
Apogee Enterprises, Inc.
4400 West 78th Street - Suite 520
Minneapolis, MN 55435

Re: Apogee Enterprises, Inc.
 Form 10-K for the fiscal year ended March 3, 2012
Filed April 30, 2012
File No. 0 -6365

Dear Mr. Porter :

We have reviewed your filing an d 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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.  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 response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have  additional comments.

Form 10 -K for the fiscal year ended March 3, 2012

Item 6. Selected Financial Data, page 16

1. If you present net cash provid ed by (used in) continuing operating activities, please revise
future filings to also  present net cash provid ed by (used in) investing and financing
activities.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 17
Results of Operations, page 19

2. We note you cite various factors that impact  your results such as volume growth, changes
in market share and changes in pricing.  Please revise future annual and quarterly filings

Mr. James S. Porter
Apogee Enterprises, Inc.
January 24, 2013
Page 2

 to quantify the impact of each factor you identify, where practicable.  Reference Release
#33-8350.

Critical Accounting  Policies, page 24
Revenue Recognition, page 25

3. With a view towards future disclosure, please help us better understand the underlying
nature of your installation business.  Please clarify if your installation business enters into
contracts or arrangement s that are separate from the other products and services you
provide.   To the extent your installation services are offered with your other products and
services;  please further explain to us how you determined each individual product or
service has stand alone value and how you allocate the total consideration in multiple
element arrangements to each individual component for revenue recognition purposes.
Reference ASC 605.

4. With a view towards future disclosure, please explain to us how the specific term s of
your contracts support revenue recognition for your installation business on a percentage -
of-completion basis and tell us the timeframes over which these contracts are performed.
In addition, please explain to us how and why you determined it was app ropriate to
measure your progress to completion in terms of costs.  Please tell us, on average, what
portion of contract costs are comprised of materials and explain to us when these costs
and the related revenues are generally recognized.  Reference ASC 6 05.

Goodwill impairment, page 25

5. With a view towards future disclosure, please help us understand how you identified your
reporting units.  Please also help us understand how you considered recent revenue
declines and losses in your Architectural segment in determining that the fair value s of
your reporting uni ts exceeded their book values.

Item 8. Financial Statements and Supplementary Data
Note 1. Summary of Significant Accounting Policies and Related Data
Self-Insurance, page 35

6. Please revise future filings to provide roll -forwards for self -insurance reserves during
each period presented.

Note 16. Business Segments Data, page 54

7. We note your disclosure on page four regarding the products and services you offer as
well as your discussion of five business units within your Architectu ral segment.  Please
provide us a specific and comprehensive discussion of how you define the operating
segments within your Architectural segment and how you determined they could be
aggregated into one reportable segment.  In order for us to more fully u nderstand your

Mr. James S. Porter
Apogee Enterprises, Inc.
January 24, 2013
Page 3

 analysis, please provide us copies of the reports provided to your chief operating decision
maker at March 3, 2012 and at December 1, 2012.  These reports should reflect actual
results and be at the lowest level of detail provided to the COD M.  Reference ASC 280.

Note 17. Commitments and Contingent Liabilities, page 55

8. We note your disclosures here and in MD&A related to additional warranty accruals in
FY 2011 due to product quality issues.  With a view towards future disclosure, please
more fully explain to us the decline in the warranty accrual in FY 2012, particularly in
light of the increase in sales.  It appears to us the product quality issues account for less
than 40% of the decline.

9. We note your disclosure that you do not believe yo ur claims will have a material adverse
effect on your financial condition.  With a view towards future disclosure, please tell us
what consideration you have given to the potential impact on your results of operations
and cash flows.  Reference ASC 450.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applica ble Exchange Act rules require.   Since the compan y and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

In responding to our comments, please provide  a written statement from the com pany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Tricia Armelin, Staff Accountant at (202) 551 -3747 or, in her absence,
Anne McConnell at (202) 551 -3709  if you have quest ions regarding these comments.

Sincerely,

 /s/ John Cash

John Cash
        Accounting Branch Chief