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Mail Stop 4561         March 10, 2008  VIA USMAIL and FAX (212) 593 - 8794  Mr. James S. Lusk Executive Vice President and Chief Financial Officer ABM Industries Incorporated 551 Fifth Avenue, Suite 300 New York, New York 10176

Re: AMB Industries Incorporated
 Form 10-K as of October 31, 2007
Filed on December 21, 2007
 File No. 001-08929

Dear Mr. James S. Lusk:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 FORM 10-K FOR THE YEAR  ENDED OCTOBER 31, 2007

Item 1, Business, page 3
1. Please provide us with documentation supporting your statement on page 4 that
ABM Engineering Services Company is “t he only national engineering services
provider of on-site opera ting engineers to earn” the ISO 9000 Certification.

James S. Lusk
ABM Industries Incorporated
March 10, 2008 Page 2
Item 3.  Legal Proceedings, page 12

2. We note disclosure on page 35 under “Contingencies and Litigation,” which states
that you have been named as a defendant in certain environmental proceedings.  Please tell us why you have not included disclosure about those proceedings in
Item 3.  Refer to Instruction 5 to Item 103 of Regulation S-K.

Item 9A.  Controls and Procedures

3. We note that you performed an evaluation of the effectiveness of the design and
operations of your disclosure controls a nd procedures and concluded they were
adequate.    Pursuant to Item 307 of Regulation S-K as amended by Release No.
33-8238:  Management’s Reports on Intern al Control over Financial Reporting
and Certification of Disclosures in Ex change Act Periodic Reports, effective
August 14, 2003, you must conclude whethe r your disclosure controls and
procedures are effective or ineffective.   Please clarif y to us what your conclusion
was.
Item 11.  Executive Compensation (incorporat ed by reference to the proxy statement)

4. Refer to the discussion of Annual Bonus  and the 2007 PIP objectives for NEOs
other than the CEO.  Please provide a significantly expanded analysis of the
bonus amounts paid to individual officers.  Disclose the target amounts for
company net income, business unit pre-tax income, days sales outstanding targets used to determine bonus amounts.  Descri be in more detail the individual and
department performance objectives.  Provi de a substantive an alysis of how the
Compensation Committee applied these objectives to determine individual compensation amounts.  Refer to Item 402(b )(2)(vii) of Regulation S-K.  Provide
this disclosure in future filings and explain to us how you intend to comply.

5. We note that incentive compensation consis ts of options, restricted stock units,
and performance shares.  Please tell us whether the performance shares are
included in the summary compensation table.  If so, provide footnote disclosure to
clarify where these amounts appear in the ta ble.  Provide this di sclosure in future
filings and explain to us how you intend to comply.

Item 13.  Certain Relationships and Relate d Transactions, and Di rector Independence

(incorporated by reference to the proxy statement)

6. Please tell us why the disclosure be ginning on page 35 of the proxy statement
does not include a discussion of the settleme nt payments to Security Services of
America, LLC.  We note the disclosure in  Note 1 to your financial statements.

James S. Lusk
ABM Industries Incorporated
March 10, 2008 Page 3
*   *   *   *

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a 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 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

James S. Lusk
ABM Industries Incorporated  March 10, 2008 Page 4   You may contact Wilson K. Lee at (2 02) 551-3468 or me at (202) 551-3498 if
you have questions regarding comments on the financial statements and related matters.
Please contact Kristina Aberg at (202) 551–3404 with any other questions.
Sincerely,     Linda Van Doorn Senior Assistant Chief Accountant