SEC Company Response from GIBRALTAR INDUSTRIES, INC. (ROCK) (CIK 0000912562) (ROCK) — Jul 29, 2013
GIBRALTAR INDUSTRIES, INC. (ROCK) (CIK 0000912562)
Date: July 29, 2013 · CIK: 0000912562 · Accession: 0001193125-13-307738
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File numbers found in text: 333-189243
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CORRESP
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CORRESP
Gibraltar Industries, Inc.
3356 Lake Shore Road
P.O. Box 2028
Buffalo, NY 14219
July 29, 2013
BY EDGAR
Securities and Exchange Commission
Division of
Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention:
Ms. Pamela Long
Assistant Director
Division of Corporation Finance
Re:
Gibraltar Industries, Inc.
Air Vent Inc.
Alabama Metal Industries Corporation
AMICO Holding Company, Inc.
Appleton Supply Company, Inc.
Construction Metals, LLC
Diamond Perforated Metals, Inc.
D.S.B. Holding Corp.
Florence Corporation
Florence Corporation of Kansas
Gibraltar Steel Corporation of New York
GSC Flight Services Corp.
Noll/Norwesco, LLC
Pacific Award Metals, Inc.
Sea Safe, Inc.
Seismic Energy Products, Inc.
Solar Group, Inc.
Southeastern Metals Manufacturing Company, Inc.
The D.S. Brown Company
Registration Statement on Form S-4
Registration No. 333-189243
Ladies and
Gentleman:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Act”), the undersigned Registrant
and Co-Registrants hereby request acceleration of the effective date of the above-referenced Registration Statement on Form S-4 (the “Registration Statement”) to 4:00 p.m., Eastern time, on July 30, 2013 or as soon thereafter as
practicable.
We acknowledge that should the Securities and Exchange Commission (the “Commission”) or the staff
acting by delegated authority declare the Registration Statement effective, (i) it does not foreclose the Commission from taking any action on the Registration Statement, and (ii) it does not relieve us from our full responsibility for the
adequacy and accuracy of the Registration Statement’s disclosure.
We further acknowledge that we may not assert the Commission’s or
staff’s comments and the declaration of the Registration Statement’s effectiveness as a defense in any proceedings initiated by the Commission or any person under the United States’ federal securities laws.
We confirm our awareness of our statutory responsibilities under the Act and the Securities Exchange Act of 1934, as amended.
Please notify Michael E. Storck, Esq. of Lippes Mathias Wexler Friedman LLP, counsel to the Registrant and Co-Registrants, at (716) 853-5100, as
soon as possible as to the time the Registration Statement has been declared effective pursuant to this acceleration request or if you require additional information.
Very truly yours,
GIBRALTAR INDUSTRIES, INC.,
and each of the co-registrants listed above
By:
/s/ Kenneth W. Smith
Name: Kenneth W. Smith
Title: Senior Vice President and Chief Financial Officer