SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

     August 3, 2006

David W. Kay
Executive Vice President, CFO and Treasurer
Gibraltar Industries, Inc.
3556 Lake Shore Road
Buffalo, NY 14219

 Re: Gibraltar Industries, Inc.
Form S-4 filed July 20, 2006
File No. 333-135908

Dear Mr. Kay:

We have limited our review of your filing to those issues we have addressed on our
comments.  Where indicated, we think you shoul d revise your documents 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 detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
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 on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Exhibit 5.1 – Opinion of Lippes Mathias Wexler Friedman LLP

1. You cannot assume that the guarantors had the power, authorization, etc., to enter into the agreements or that the substantive laws of the Foreign Jurisdictions and the substantive laws of the State of New York are the same in all material respects, but you can expressly rely on ot her opinions. Each such other opinion
must reflect that you are permitted to rely on it.

2. Where counsel refers to the Delaware General Corporation Law, counsel should
confirm supplementally that it does not intend to exclude the Delaware
Constitution and reported judicial decisi ons interpreting these laws.  Counsel
should file this correspondence on EDGAR, as it will be a part of the Commission’s official file regarding this registration statement.  See Section
VIII.A.14 of our November 14, 2000 Current Issues Outline.

David W. Kay
Gibraltar Industries, Inc. August 3, 2006
Page 2
 As appropriate, please amend your filing in response to these comments.  You may wish to provide us with marked copies of the amendment to e xpedite our review.
Please furnish a cover letter with your amendment that ke ys your responses to our
comments and provides any requested inform ation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed 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.

 Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:

‚ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose th e Commission from taking any action with
respect to the filing;

‚ the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective,  does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

‚ the company may not assert this action 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 advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the
registration statement as a confirmation of th e fact that those reque sting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
 We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

David W. Kay
Gibraltar Industries, Inc. August 3, 2006
Page 3
Please direct questions to Brigitte Li ppmann, at (202) 551-3713, or me at (202)
551-3767.

Sincerely,

Jennifer Hardy
Branch Chief

cc: Michael E. Storck, Esq.
 Lippes Mathias Wexler Friedman LLP
 665 Main Street, N.E., Suite 300
 Buffalo, NY 14203