SEC Comment Letter for ABM INDUSTRIES (ABM) — May 3, 2016

ABM INDUSTRIES INC /DE/ (ABM) (CIK 0000771497)
Date: May 3, 2016 · CIK: 0000771497 · Accession: 0000000000-16-074732

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File numbers found in text: 001-08929

Date

May 3, 2016

Author

/s/ Daniel L. Gordon

Form

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Company

ABM INDUSTRIES INC /DE/ (ABM) (CIK 0000771497)

Letter

Mail Stop 3233 May 3, 2016 Via E -mail Mr. D. Anthony Scaglione Executive Vice President and Chief Financial Officer ABM Industries Incorporated 551 Fifth Avenue, Suite 300 New York, NY 10176

Re: ABM Industries Incorporated Form 10 -K for the fiscal year ended October 31, 2015 Filed December 17, 2015 File No. 001-08929

Dear Mr. Scaglione :

We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or a ny person under the federal securities laws of the United States. 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 1 934 and all applicable rules require.

Sincerely,
/s/ Daniel L. Gordon

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Mail Stop 3233
May 3, 2016

Via E -mail
Mr. D. Anthony Scaglione
Executive Vice President and Chief
Financial Officer
ABM Industries Incorporated
551 Fifth Avenue, Suite 300
New York, NY 10176

Re: ABM Industries Incorporated
Form 10 -K for the fiscal year ended October 31, 2015
Filed December 17,  2015
            File No. 001-08929

Dear Mr. Scaglione :

 We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or a ny person under the
federal securities laws of the United States.  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 1 934 and all applicable rules require.

Sincerely,

 /s/ Daniel L. Gordon

Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities

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