SecProbe.io

August 5, 2024
Timothy F. Murphy
Senior Vice President and Chief Financial Officer
Gibraltar Industries, Inc.
3556 Lake Shore Road
Buffalo, New York 14219
Re:Gibraltar Industries, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
Response Dated June 24, 2024
File No. 000-22462
Dear Timothy F. Murphy:
            We have reviewed your June 24, 2024 response to our comment letter and have the
following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless we
note otherwise, any references to prior comments are to comments in our June 10, 2024 letter.
Form 10-K for the fiscal year ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Estimates
Revenue Recognition on Contracts with Customers, page 29
We note your response to prior comment 1; however, we also note Item 303(b)(3) of
Regulation S-K requires for each critical accounting estimate (CAE) made in accordance
with generally accepted accounting principles that involves a significant level of
estimation uncertainty and had or is reasonably likely to have a material impact on
financial condition or results of operations you address the following: why the CAE is
subject to uncertainty; how much the CAE or assumption (or both) changed during the
relevant periods; and the sensitivity of reported amounts to the methods, assumptions, and
estimates underlying the CAE’s calculation. Based on the requirements and the
information provided in your response, it appears you should revise future filings to
disclose and discuss the impact of favorable and unfavorable changes in contract 1.

August 5, 2024
Page 2
estimates and estimated contract losses during each period presented. If you believe the
disclosures are not material, please provide your SAB 99 materiality analysis of the
factors you considered in your assessment. Please be advised since these estimates impact
Operating Income and Net Income, any materiality assessment you provide should not be
limited to the impact on revenue and gross profit. In addition, please tell us your
consideration of the disclosure requirements of ASC 250-10-50-4.

Notes to Consolidated Financial Statements
(3) Revenue, page 46
2.We note your response to prior comment 2 states costs in excess of billings represent
contract assets and your right to this consideration is conditioned on something other than
the passage of time; however, we also note accounts receivable and costs in excess of
billings are presented in the same line item in your consolidated balance sheets.
Notwithstanding your disclosures of accounts receivable and costs in excess of billings in
the notes to the financial statements, it is not clear how you determined the current
presentation in your consolidated balance sheets complies with ASC 606-10-45-1. Please
advise or revise future filings as appropriate.
Form 8-K filed February 21, 2024
Exhibit 99.1, page 1
3.We note your responses to prior comments 7 and 8. Please revise future filings to address
the following:
•We acknowledge your non-GAAP reconciliations exclude certain line items included
in your statements of operations; however, we note your reconciliations include
every line item from the subtotal for Income from Operations through earnings per
share. We continue to believe your current presentations includes most of the line
items and subtotals included in your statements of operations and should be revised in
future filings to comply with Question 102.10(c) of the Compliance and Disclosure
Interpretations for Non-GAAP Financial Measures.
•We note your non-GAAP reconciliations include a subtotal you identify as “Segments
income”. Since the subtotal represents a non-GAAP measure that does not comply
with Question 100.01 of the Compliance and Disclosure Interpretations for Non-
GAAP Financial Measures, revise your reconciliations in future fling to delete this
subtotal.
•Revise your non-GAAP reconciliations in future filing to clearly explain and describe
each non-GAAP adjustment as required by Question 100.05 of the Compliance and
Disclosure Interpretations for Non-GAAP Financial Measures.

August 5, 2024
Page 3
            Please contact Andi Carpenter at 202-551-3645 or Anne McConnell at 202-551-3709 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing