SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631

DIVISION OF
CORPORATION FINANCE
         November 5, 2014

Via E-Mail
Mr. Ronald J. Knutson
Chief Financial Officer
Lawson Products Inc/New/DE
8770 W. Bryn Mawr Ave, Suite 900
Chicago, IL  60631

 Re: Lawson Products Inc/New/DE
  Form 10 -K for Fiscal Year Ended December 31, 2013
Filed February 20, 2014
  Form DEF 14A
  Filed March 28, 2014
  File No.   0-10546

Dear Mr.  Knutson :

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

Definitive Proxy Statement

Proxy card

1. In future filings  please ensure that the proxy card clearly indicates that shareholders are
being asked to vote, on an advisory basis, to approve executive compensation.  For
additional guidance, please see Question 169.07 of the Exchange Act Rules Compliance
and Disclosur e Interpretations.

Mr. Ronald Knutson
Lawson Products Inc/New/DE
November 5, 2014
Page 2

 Closing Comments

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 Exc hange 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 t he 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
foreclose the C ommission 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 S herry Haywood  at (202) 551 -3345 , with questions regarding these
comments , or me at (202) 551 -3768  with any other questions.

        Sincerely,

/s/ W. John Cash

W. John Cash
Branch Chief