SecProbe.io

November 27 , 2013

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

RE: Apogee Enterprises , Inc .
Form 10 -K for the Year E nded March 2, 2013
Filed May 16, 2013
Definitive Proxy Statement on Schedule 14A
Filed May 16 , 2013

  File No. 0-6365

Dear Mr. Porter :

We have reviewed your filing s 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 within ten business days by providing the requested
information or by advising us when you will provide the requested respon se.  If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for the Year End ed March 2, 2013

Backlog, page 8

1. To the extent that certain contracts or projects comprise a material portion of your
backlog, in future filings please consider enhancing your disclosure to specifically
identify these contracts and any inherent risks ass ociated with backlog work being
performed.   For example, we note that during the earnings call for the fourth quarter of
2013, Mr. Puishy referred to the backlog as “architectural backlog” and discussed how
the projects that “have been awarded” mature and count towards the backlog.   If projects
are being awarded on a competitive/bid basis, please revise your future filings to enhance

Mr. James S. Porter
Apogee Enterprises, Inc.
November 27 , 2013
Page 2

 this aspect of your disclosure.  Please also disclose backlog amounts for each
segment.   Refer to Item 101(c)(1)(viii) of Reg ulation S -K.

Risk Factors, page 10

2. In future filings , please ensure that each risk factor is set under a subcaption that
adequately describes the risk.

Definitive Proxy Statement filed May 16, 2013

Executive Compensation, page 24
Long -Term Incentive Compensation, page 37
Cash -Based Performance Awards, page 38

3. At the beginning of page 39, you disclose that the dollar value of the cash award is
determined as a percentage of base salary.  In future filings, please revise your tabular
disclosur e in the middle of page 39 to include these percentages.

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 applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the company
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 f oreclose
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.

Mr. James S. Porter
Apogee Enterprises, Inc.
November 27 , 2013
Page 3

 You may contact Asia Timmons -Pierce , Staff Attorney , at (202) 551 -3754 or, in h er
absence, Era Anagnosti , Staff Attorney , at (202) 551 -3369 if you have any questions regarding
legal matters.  Please contact Nudrat Salik, Staff Accountant, at (202) 551 -3692  or, in her
absence, me  at (202) 551 -3355  if you have questions regarding comments on the financial
statements and related matters.

       Sincerely,

       /s/ M elissa N. Rocha for

Terence O’Brien
       Accounting Branch Chief