SecProbe.io

July 8, 2013
Via E -Mail
Brian J. Lipke
Chairman of the Board and Chief Executive Officer
Gibraltar Industries, Inc.
3556 Lake Shore Road
Buffalo, New York  14219

Re: Gibraltar Industries, Inc.
  Registration Statement on Form S-4
Filed  June 12, 2013
  File No.  333-189243

Dear Mr. Lipke :

We have limited our review of your registration statement to those issues we have
addressed in our 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 by amending your registration statement and providing the
requested information .  Where 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 any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

General
1. We note that you are registering the 6.25% senior subordinated notes due 2021 in
reliance on our position enunciated in Exxon Capital Holdings Corp., SEC No -Action
Letter (April 13, 1988).  See also Morgan Stan ley & Co. Inc., SEC No -Action Letter
(June 5, 1991) and Shearman & Sterling, SEC No -Action Letter (July 2, 1993).
Accordingly, with the next amendment, please provide us with a supplemental letter
stating that you are registering the exchange offer in rel iance on our position contained in
these letters and include the representations contained in the Morgan Stanley and
Shearman & Sterling no -action letters.

Terms of the Exchange Offer, page 25

2. We note disclosure indicating that pursuant to the Rule 14e -1(c) of the Exchange Act,
you will promptly deliver the new notes “upon consummation of the exchange offer” or
return the original notes if the exchange offer is withdrawn.  Rule 14e -1(c) requires that

Brian J. Lipke
Gibraltar Industries, Inc.
July 8, 2013
Page 2

 you exchange the notes or return the old notes “promptl y” upon expiration or termination
of the offer, as applicable.  Please revise here and throughout the document as necessary.
We note that the third paragraph on page 28 contains the required disclosure.

Expiration Date; Extensions; Amendment, page 27

3. We note disclosure that the offer will be open for 30 days after the commencement of the
exchange offer.  Please confirm supplementally that the offer will be open for at least 20
full business days to ensure compliance with Rule 14e -1(a).  Further, please c onfirm that
the expiration date will be included in the final prospectus disseminated to security
holders and filed pursuant to the applicable provisions of Rule 424.

4. As currently represented, the offer could be open for less than 20 full business days du e
to the 5:00 p.m. expiration time instead of an expiration time of midnight on what
ultimately may be the twentieth business day following commencement.  See Question
and Answer Eight in Exchange Act Release No. 16623 (March 5, 1980).  Please confirm
that the offer will be open at least through midnight on the twentieth business day.  See
Rule 14d -1(g)(3).

5. We note your reservation of the right to amend the te rms of the offer.  Please revise to
indicate that, in the event of a material change in the offer, including the waiver of a
material condition, you will extend the offer period if necessary so that at least five
business days remain in the offer following  notice of the material change.

6. You reserve the right “to delay the acceptance of any original notes.”  Clarify in what
circumstances you will delay acceptance and confirm that any such delay will be
consistent with Rule 14e -1(c).  For example, if you are  referring to the right to delay
acceptance only due to an extension of the exchange offer, so state.

7. Please advise us as to how oral notice of any extension is reasonably calculated to reach
registered holders of the outstanding notes or otherwise satisf ies the requirements of Rule
14e-1(d).

Form of Letter of Transmittal - Exhibit 99.1

8. Please delete the language in the first sentence on the second page of the letter of
transmittal requiring the holder to acknowledge that he or she has “reviewed” the
prospectus.  Please also delete the language in the last two paragraphs on page six
requiring the holder to acknowledge that he or she “understands” certain terms of the
exchange offer.

Legal Opinion, Exhibit 5.1

9. We note that counsel’s opinion expressly exc ludes all law other than federal law and the

Brian J. Lipke
Gibraltar Industries, Inc.
July 8, 2013
Page 3

 laws of the States of New York and Delaware.  Please note our view that an opinion that
a debt security or guarantee is a binding obligation necessarily encompasses the opinion
that the registrant is validly exi sting, has the power to create the obligation and has taken
the required stops to authorize entering into the opinion.  As counsel is admitted to
practice law in the State of New York, it may opine on New York law and we will not
object to its opinion rega rding Delaware law.  However, you must file local counsel
opinions for each subsidiary guarantor not organized or incorporated in New York or
Delaware to opine that each such subsidiary guarantor is validly existing, has the power
to create the guarantee o bligation and has taken the required steps to authorize entering
into the obligation under the law of the jurisdiction of organization.  New York counsel
may then rely on these opinions or assume matters involving local law.  See Section
II(B)(1)(e) of Sta ff Legal Bulletin No.19 (CF) dated October 14, 2011.

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 Act of 193 3 and
all applicable  Securities  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 the disclosures they have made.

Notwithstanding our comments, i n the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare th e
filing effective, it does not foreclose the 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 staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under  the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Brian J. Lipke
Gibraltar Industries, Inc.
July 8, 2013
Page 4

 Please contact Sherry Haywood, Staff Attorney at (202) 551 -3345  or, in her absence,  me
at (202) 551 -3760  with any other questions.

Sincerely,

 /s/ Pamela Long

 Pamela Long
Assistant Director

Cc: Via E -Mail
 Michael E. Storck, Esq.