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May 11, 2020
Brian L. MacNeal
Chief Financial Officer
Armstrong World Industries, Inc.
2500 Columbia Avenue
Lancaster, Pennsylvania 17603
Re:Armstrong World Industries, Inc.
Form 10-K for the Year Ended December 31, 2019
Response dated April 15, 2020
File No. 001-02116
Dear Mr. MacNeal:
            We have reviewed your April 15, 2020 response to our comment letter 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 within ten business days 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.  Unless we note otherwise, our references to prior comments are to comments in our
March 25, 2020 letter.
Form 10-K for the Year Ended December 31, 2019
Financial Statements
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revision of Previously Issued Financial Statements, page 44
1.We are continuing to evaluate your response to prior comment 1 and may have additional
comments.
Item 9A. Controls and Procedures, page 87
2.We note from your response to prior comment 1 that you identified an error in the
calculation of the loss on disposal of discontinued operations recorded in the year ended

 FirstName LastNameBrian L. MacNeal
 Comapany NameArmstrong World Industries, Inc.
 May 11, 2020 Page 2
 FirstName LastName
Brian L. MacNeal
Armstrong World Industries, Inc.
May 11, 2020
Page 2
December 31, 2017.  Please address the following with regard to your internal control
over financial reporting (ICFR) and disclosure controls and procedures (DCP):

•Explain to us how the error was discovered, and by whom.  Include in your response
further details on the nature of the error and the reason(s) for the impact on each
financial statement line item affected.

•To the extent that you determined there were control deficiencies that lead to the
incorrect accounting for the noted transaction, describe in reasonable detail the
control(s) that failed and how you evaluated the severity of each identified control
failure for each period it existed.  Refer to the guidance for evaluation of control
deficiencies beginning on page 34 of SEC Release No. 33-8810 “Commission
Guidance Regarding Management’s Report on Internal Control Over Financial
Reporting Under Section 13(a) or 15(d) of the Securities Exchange Act of 1934.”
 Include in your analysis a description of the maximum potential amount or total
amount of transactions exposed to the deficiency and explain how you made that
determination.

•Tell us whether you evaluated if there were any deficiencies in your monitoring or
risk assessment controls and processes as a result of the identified transaction, and if
so, how you evaluated the severity of those deficiencies.

•Tell us of any changes or improvements in your internal controls over financial
reporting you made or plan to make as a result of your detection of the incorrect
accounting for this transaction including the timing of such changes.

•Please tell us how you considered any identified controls deficiencies in your
assessments of the effectiveness of DCP and ICFR in your Form 10-K for the year
ended December 31, 2017 and for subsequent applicable periodic reports.

            You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551-3379
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing