SecProbe.io

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                                   LESCO, Inc.
                        1301 East 9th Street, Suite 1300
                              Cleveland, Ohio 44114

                                  May 31, 2005

VIA EDGAR CORRESPONDENCE

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Attention:  Michael Moran, Branch Chief
            Division of Corporation Finance

           Re: LESCO, Inc. (the "Company")
               Form 10-K for the year ended December 31, 2004
               File No. 0-13147

Dear Mr. Moran:

      This letter responds to the comment letter from the staff of the
Securities and Exchange Commission (the "Commission") dated May 3, 2005,
regarding the Company's Annual Report on Form 10-K for the year ended December
31, 2004. For the convenience of the staff, we have repeated the text of the
staff's comments, followed by the Company's response. A courtesy copy of this
letter is being sent to you via facsimile.

FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations, page 10

Consolidated Results

1.    We note the adjustments to GAAP in the consolidated statement of
      operations throughout MD&A. Since you indicate you use the adjusted
      results as a performance measure, tell us, and disclose in future filings,
      the following items:

      -     The manner in which management uses the non-GAAP measure to conduct
            or evaluate its business;

      -     The economic substance behind management's decision to use such a
            measure;

      -     The material limitations associated with use of the non-GAAP
            financial measure as compared to the use of the most directly
            comparable GAAP financial measure;

      -     The manner in which management compensates for these limitations
            when using the non-GAAP financial measure;

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Mr. Michael Moran
Securities and Exchange Commission
Page 2 of 15

      -     The substantive reasons why management believes the non-GAAP
            financial measure provides useful information to investors; and

      -     Item 10(e) of Regulation S-K prohibits adjusting a non-GAAP
            financial performance measure to eliminate or smooth items
            identified as non-recurring, infrequent or unusual, when the nature
            of the charge is such that it is reasonably likely to recur within
            two years or there was a similar charge within the past two years.
            Clearly demonstrate that these adjustments meet the requirements of
            Item 10(e).

      Refer to in Question #8 from the SEC Staff Views on Frequently Asked
      Questions Regarding the Use of Non-GAAP Financial Measures dated June 13,
      2003, which can be found on the SEC website.

      RESPONSE: The Company will include substantially the following disclosure
within MD&A in future filings that contain the adjustments shown in the
Form 10-K:

            The consolidated statements of operations below set forth our
      results reported under generally accepted accounting principles (GAAP) and
      adjusted for items that are either infrequent or will aid the reader of
      the information in analyzing comparability between prior periods. We use
      the adjusted results (i) as an indication of how effectively the Company
      would have operated in a year without the adjusted items and (ii) in
      calculating the portion of management annual bonuses payable based on a
      basic earnings per share target, as described in our proxy statement. The
      adjustments also eliminate our previously discussed strategic initiatives.
      We believe that the adjusted results are an appropriate depiction of our
      future cash requirements as we do not expect to use cash in the future
      to satisfy the items for which adjustments were made.

            We recognize the limitations of the adjusted results as compared to
      GAAP net income (loss). The adjusted results should not be considered as
      an alternative to GAAP net income (loss). Rather, the adjusted results are
      simply an additional indicator of the Company's operating performance. We
      encourage readers to rely on our GAAP results, but we included the
      adjusted information as supplemental information to assist readers in
      analyzing comparability between periods.

            A reconciliation to GAAP of our adjusted financial results is as
      follows:"

      The Company recognizes that Item 10(e) of Regulation S-K prohibits the use
of a non-GAAP financial performance measure to eliminate or smooth items
identified as non-recurring, infrequent or unusual, when the nature of the
charge is such that there was a similar charge in the past two years or that it
is reasonably likely to recur within two years. Although the Company has not
characterized the specific adjustments in the Form 10-K as non-recurring,
infrequent or unusual, the Company believes the adjustments set forth in the
Form 10-K satisfy Item 10(e) for the following reasons:

<PAGE>

Mr. Michael Moran
Securities and Exchange Commission
Page 3 of 15

      1.    Cost of inventory markdown/Vendor contract termination - The Company
            has not incurred a charge for termination of a long-term vendor
            contract related to product for resale or a related markdown of
            inventory during the past two years. The Company terminated the
            agreement because it was unable to profitably sell the product
            purchased pursuant to the agreement. The Company does not currently
            have any long-term purchase commitments for product for resale. As a
            result, management believes it is not reasonably likely that the
            Company will terminate such a contract and incur a related markdown
            of inventory within the next two years.

            The Company did incur a charge related to the markdown of inventory
            in 2002 in connection with implementation of an inventory product
            life cycle program. Under this program, products are written down
            and sold at the end of their life cycle because they have been or
            are going to be replaced by other products. The inventory markdown
            in 2002 related to products included in inventory that had reached
            the end of their life cycle. The inventory marked down in connection
            with termination of the vendor contract had not reached the end of
            its life cycle, but rather was written down solely as a result of
            the contract termination.

      2.    Early retirement of debt agreement - The Company was recapitalized
            as a result of and in connection with the sale of the Company's
            accounts receivable to GE Business Credit Services (GEBCS). This
            recapitalization included redemption of the Company's preferred
            shares, reduction of indebtedness by $57,000,000 and refinancing of
            the Company's credit facility and would not have occurred without
            the sale of accounts receivable. The sale of accounts receivable and
            related debt reduction were part of a complete restructuring of our
            capital structure to outsource our private label credit program.
            There has not been a similar recapitalization transaction in the
            last two years and we do not expect another in the foreseeable
            future.

      3.    Loss from sale of accounts receivable - The Company did not incur a
            charge for loss from sale of accounts receivable during 2004 or the
            two years preceding 2003. As (i) the sale of accounts receivable to
            GEBCS was a component of a recapitalization transaction entered into
            as part of the outsourcing of the private label credit program, (ii)
            the private label credit program has had a positive impact on the
            Company's financial condition and (iii) the Company no longer has
            material amounts of accounts receivable as a result of that program,
            it is not reasonably likely that the Company will incur charges for
            loss from the sale of accounts receivable within the next year.

      4.    Corporate relocation expense - The Company also has not incurred
            charges for relocation of its corporate headquarters within the past
            two years. Given that the Company is party to a new five-year lease
            for its corporate headquarters that met the Company's objective of
            reducing its leased square footage and related costs, it

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Mr. Michael Moran
Securities and Exchange Commission
Page 4 of 15

            is not reasonably likely that the Company will incur charges for
            relocation of its corporate headquarters within the next two years.

      5.    Hurricane/flood expense - The Company has not in the past incurred
            expenses as a result of damage to its assets due to flood and has
            not in at least the last twenty years incurred expense as a result
            of damage due to hurricane activity. Based on that history, the
            Company does not believe it is reasonably likely to incur such
            charges in the next two years.

      6.    Income tax (provision) benefit - The Company included an income tax
            provision adjustment because the foregoing adjustments would result
            in the Company having taxable income. In addition, the Company
            believes it will have taxable income in future years. It is the
            Company's opinion that adjusting for the aforementioned items and
            failing to adjust for a tax provision would provide an inadequate
            and misleading view of what the Company believes its performance
            will be in the future.

2004 vs. 2003 - Pre-Tax Earnings

2.    Similar to the comment above, revise your disclosures in future filings
      for the non-GAAP financial measure `Adjusted pre-tax earnings.' Show us
      what your revised disclosures will look like.

      RESPONSE: The Company will cross-reference to its disclosure concerning
adjustments to GAAP net income (loss) set forth in the response to comment 1 and
will include the following specific disclosure with respect to the non-GAAP
financial measure `Adjusted pre-tax earnings':

            "We recognize the limitations of Adjusted pre-tax earnings as
      compared to GAAP pre-tax loss. Adjusted pre-tax earnings should not be
      considered as an alternative to GAAP pre-tax loss. Rather, Adjusted
      pre-tax earnings is simply an additional indicator of the Company's
      operating performance. We encourage readers to rely on our GAAP results,
      but we included the adjusted information as supplemental information to
      assist readers in analyzing comparability between periods."

Business Segment Results

3.    Please provide the disclosures requested in comment 1 above for the
      non-GAAP financial measures `ROIC,' `EBIT,' `NOPAT,' and `Invested
      Capital.' Show us what your revised disclosure will look like.

      RESPONSE: The Company will include substantially the following disclosure
within MD&A in future filings containing ROIC, EBIT, NOPAT and Invested Capital:

<PAGE>

Mr. Michael Moran
Securities and Exchange Commission
Page 5 of 15

            "We believe that return on invested capital (ROIC), which is a
      non-GAAP financial measure because its components include non-GAAP
      financial measures, provides an additional and useful means to assess our
      performance. ROIC is frequently used by securities analysts, investors,
      including a number of our shareholders, and other interested parties to
      evaluate the performance of a company.

            ROIC reflects the return we are receiving on our investment and is
      used by us to direct capital to opportunities with high return potential
      and away from opportunities with low return potential. For example, we
      decided to explore strategic alternatives with respect to our
      manufacturing and supply chain assets once current management determined
      that ROIC for those assets was lower than ROIC for our Selling segment. We
      allocate resources, including working, fixed and leased capital, to
      existing and potential selling locations based upon projected sales and
      ROIC. ROIC is also one of the financial measures upon which management
      annual bonuses are based.

            Traditionally, analysts and investors define ROIC as net operating
      profit (otherwise known as earnings before interest and taxes or "EBIT")
      adjusted for the payment of taxes (NOPAT) divided by invested capital. For
      the Selling segment, we calculate ROIC as follows:

      ROIC=                NOPAT/Invested Capital
      NOPAT=               Selling Segment EBIT X 61% (1 - effective tax rate)
      Invested Capital=    Accounts Receivable (excluding rebate receivable -
                           see Note 3 to Consolidated Financial Statements);
                           plus Inventory (excluding capitalized distribution
                           and procurement costs, markdown and shrink reserves
                           and credit for inventory held on consignment - see
                           Note 4 to Consolidated Financial Statements); plus
                           Fixed Capital (see Note 5 to Consolidated Financial
                           Statements).

            Our calculation of ROIC may not be similar to other similarly titled
      captions used by analysts, investors and other companies. For example, we
      do not capitalize operating leases or utilize average invested capital
      over given periods.

            EBIT, which we use in calculating ROIC, is a non-GAAP financial
      measure. EBIT reflects our earnings before the payment of interest on
      indebtedness and taxes. EBIT is used in calculating ROIC because
      traditionally analysts and investors, as well as the Company, have not
      included the cost of the capital invested in determining the return on
      that capital. The cost of the capital invested by the Company is reflected
      by the payment of interest on indebtedness. In addition to using EBIT in
      calculating ROIC, we use EBIT as a measure of the profitability of our
      operations because it excludes the effects of our capitalization structure
      and taxes. Neither capitalization structure nor taxes reflect the

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Mr. Michael Moran
Securities and Exchange Commission
Page 6 of 15

      efficiency of operation of our assets. Finally, we use EBIT in determining
      whether to finance a project with debt or equity.

            Traditionally, investors and analysts, as well as the Company,
      adjust EBIT in calculating ROIC to reflect the expected percentage of
      taxes that will be paid on EBIT. EBIT as adjusted for the expected
      percentage of tax that will be paid is known as "NOPAT." NOPAT reflects
      the estimated after tax profit of the Company excluding the effect of the
      Company's cost of capital. NOPAT reflects the return the Company is
      receiving on its investment separate from the cost of financing that
      investment.

            Invested Capital reflects the amount of capital invested by us. The
      Company complies with GAAP segment reporting as it analyzes its business
      by the Selling and Support segments. Invested Capital with respect to our
      Selling segment reflects invested capital only with respect to that
      segment calculated in accordance with GAAP. Rebates receivable ar