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CORRESP

 July 10, 2023

Correspondence Filing Via EDGAR

 United States
Securities and Exchange Commission

 Division of Corporation Finance

Office of Trade & Services

 100 F Street, NE

Washington, DC 20549

 Attention: Amy Geddes; Lyn Shenk

Re: WESCO International, Inc.

 Form 10-K for Fiscal Year Ended December 31, 2022

 File No. 001-14989

 Filed February 21, 2023

 Dear Amy Geddes
and Lyn Shenk:

 We have set forth below the response of WESCO International, Inc. (“Wesco” or the “Company”) to address the comments
of the Staff of the Division of Corporation Finance contained in your letter dated June 26, 2023 regarding your review of Wesco’s filing noted above.

For your convenience, we have restated in bold type the Staff’s comments followed by each of our responses.

Form 10-K for Fiscal Year Ended December 31, 2022

Management’s Discussion and Analysis

Results of Operations, page 27

 Comment
No. 1:

 For expenses allocated to reportable segments, please revise to discuss and analyze expenses by segment.

Response:

 The Company respectfully
acknowledges the Staff’s comment and advises that we will include a discussion and analysis of expense variances by reportable segment (i.e., cost of goods sold, selling, general and administrative expenses, and depreciation and amortization)
in any future filings in which we include a Management’s Discussion and Analysis, beginning with the Form 10-Q for the quarterly period ended June 30, 2023.

 1

 For illustrative purposes, below is the Company’s proposed disclosure using the above-referenced
2022 Form 10-K as a model. Revisions have been marked to facilitate the Staff’s review. The Company will endeavor to provide similar levels of disclosure in future filings. Note that the first paragraph
under Cost of Goods Sold below does not reflect the changes that are marked in response to Comment No. 2 below.

 Cost of
Goods Sold

 Cost of goods sold for 2022 was $16.8 billion compared to $14.4 billion for
2021, an increase of $2.4 billion. Cost of goods sold as a percentage of net sales was 78.2% and 79.2% for 2022 and 2021, respectively. The favorable reduction of 100 basis points reflects our focus on value-driven pricing and pass-through of
inflationary costs, along with the continued momentum of our gross margin improvement program and higher supplier volume rebates as a percentage of net sales. Cost of goods sold for 2021 included a write-down to the carrying value of certain
personal protective equipment inventories, which increased cost of goods sold as a percentage of net sales by approximately 14 basis points.

Cost of goods sold for EES, CSS and UBS increased by $860.0 million,
$471.4 million and $1,001.9 million, respectively, year-over-year. These increases in cost of goods sold by segment primarily reflect the factors impacting the overall business, as described above. Cost of goods sold for CSS in 2021 also
included a write-down to the carrying value of certain personal protective equipment inventories of $21.1 million.

Selling, General and Administrative Expenses

SG&A expenses primarily include payroll and payroll-related costs, shipping and handling, travel and
entertainment, facilities, utilities, information technology expenses, professional and consulting fees, credit losses, gains (losses) on the sale of property and equipment, as well as real estate and personal property taxes. SG&A expenses for
2022 totaled $3.0 billion versus $2.8 billion for 2021, an increase of $252.6 million, or 9.0%. As a percentage of net sales, SG&A expenses were 14.2% and 15.3% for 2022 and 2021, respectively. SG&A expenses for 2022 include
merger-related and integration costs of $67.4 million. Adjusted for this amount, SG&A expenses for 2022 were 13.9% of net sales. SG&A expenses for 2021 include merger-related and integration costs of $158.5 million, as well as a
net gain of $8.9 million resulting from the Canadian divestitures. Adjusted for these amounts, SG&A expenses were 14.5% of net sales for 2021.

SG&A payroll and payroll-related expenses for 2022 of $1.9 billion increased by $128.7 million
compared to 2021 primarily as a result of higher salaries due to wage inflation and increased headcount, as well as an increase in commissions driven by significant sales growth, partially offset by a reduction to incentive compensation expense.

 SG&A expenses not related to payroll and payroll-related costs for 2022 were $1.1 billion, an
increase of $123.9 million compared to 2021. The increase primarily reflects higher volume-related costs driven by significant sales growth and digital transformation initiatives that contributed to higher expenses in 2022, including those
related to professional and consulting fees, as well as the absence of the net gain recognized in the first quarter of 2021 on the Canadian divestitures. These increases were partially offset by the realization of integration cost synergies and
lower costs associated with integration activities.

 2

 SG&A expenses for EES, CSS and UBS increased by $98.1 million, $98.9 million and $73.8 million, respectively, year-over-year. These increases were primarily
attributed to higher SG&A payroll and payroll-related expenses which increased by $73.5 million, $70.9 million, and $39.6 million, respectively, as a result of higher salaries due to wage inflation and increased headcount, as well as
an increase in commissions driven by significant sales growth, partially offset by a reduction to incentive compensation expense compared to the prior year. Additionally, increases in transportation costs of $18.1 million, $17.4 million,
and $16.0 million for EES, CSS and UBS, respectively, contributed to the year-over-year increases in SG&A expenses as a result of significant sales growth. The absence of the net gain of $8.9 million recognized in 2021 on the Canada
divestitures also contributed to the net increase in SG&A for UBS.

Depreciation and Amortization

Depreciation and amortization decreased $19.6 million to $179.0 million for 2022, compared to
$198.6 million for 2021. Depreciation and amortization for 2022 and 2021 includes $9.8 million and $32.0 million, respectively, of accelerated amortization expense resulting from changes in the estimated useful lives of certain legacy
trademarks that are migrating to our master brand architecture, as described in our overall results above.

EES and CSS depreciation and amortization decreased $13.4 million and
$14.4 million, respectively, year-over-year, primarily as a result of decreases in accelerated amortization expense of $9.7 million and $13.0 million, respectively. UBS depreciation and amortization remained relatively flat
year-over-year.

 Comment No. 2:

Please explain to us and revise to disclose what “workday impact” represents and what “value-driven pricing” means.

Response:

 The Company respectfully
acknowledges the Staff’s comment. “Workday impact” represents the estimated impact that the change in the number of non-holiday weekdays from period to period has on the change in net sales from
one period to another. We will disclose an explanation of what “workday impact” represents in future filings beginning with the Form 10-Q for the quarterly period ended June 30, 2023.

 3

 “Value-driven pricing” refers to Wesco’s strategy of pricing products and services to
realize the value that we provide to our customers as a result of our broad portfolio of product and service offerings, global footprint and capabilities, as opposed to just pricing products based on a percentage markup of cost. We will disclose an
explanation of “value-driven pricing” in future filings beginning with the Form 10-Q for the quarterly period ended June 30, 2023.

For illustrative purposes, below is the Company’s proposed disclosure using the above-referenced 2022 Form
10-K as a model. Revisions have been marked to facilitate the Staff’s review. The Company will endeavor to provide similar levels of disclosure in future filings.

Net Sales

The following table sets forth net sales and organic sales growth by segment for the periods presented:

Twelve Months Ended

Growth/(Decline)

  (In thousands)

December 31,
2022

December 31,
2021

Reported

Acquisition/
Divestiture
Impact

Foreign
Exchange
Impact

Workday
Impact

Organic
    Growth

   EES

$
8,823,331

$
7,621,263

15.8%

(0.1)%

(1.8)%

0.4%

17.3%

   CSS

6,401,468

5,715,238

12.0%

 2.0 %

(1.9)%

0.4%

11.5%

   UBS

6,195,317

4,881,011

26.9%

(0.1)%

(0.6)%

0.4%

27.2%

   Total net sales

$
      21,420,116

$
      18,217,512

17.6%

 0.5 %

(1.5)%

0.4%

18.2%

 Note: Organic sales growth is a non-GAAP
financial measure of sales performance. Organic sales growth is calculated by deducting the percentage impact from acquisitions and divestitures for one year following the respective transaction, fluctuations in foreign exchange rates and number of
workdays from the reported percentage change in consolidated net sales. Workday impact represents the change in the number of operating days period-over-period after
adjusting for weekends and public holidays in the United States; 2022 had one additional workday compared to 2021.

Cost of Goods Sold

Cost of goods sold for 2022 was $16.8 billion compared to $14.4 billion for 2021, an increase of $2.4 billion.
Cost of goods sold as a percentage of net sales was 78.2% and 79.2% for 2022 and 2021, respectively. The favorable reduction of 100 basis points reflects our focus on a
strategy of pricing products and services to realize the value that we provide to our customers as a result of our broad portfolio of product and service offerings, global footprint and capabilities (“value-driven pricing”). Additionally, pass-through of inflationary costs, along with the continued momentum of our gross margin improvement program
and higher supplier volume rebates as a percentage of net sales contributed to the favorable reduction in cost of goods sold as a percentage of net sales. Cost of goods sold for 2021 included a write-down to the carrying value of certain personal protective equipment inventories, which increased cost of goods sold as a percentage of net sales by approximately 14
basis points.

 4

 Management’s Discussion and Analysis

Results of Operations, page 27

 Comment
No. 3:

 Please revise to quantify factors to which changes are attributed. For example, you state the increase in net sales primarily reflects
price inflation and volume growth. Refer to Item 303(b)(2)(iii) of Regulation S-K.

 Response:

 The Company respectfully acknowledges the Staff’s comment. Wesco sells millions of products to approximately 150,000 customers across
many industries, as described in Item 1. Business of our Form 10-K for the year ended December 31, 2022. These products vary in terms of pricing and the volumes at which they are sold and therefore, the
Company cannot precisely quantify the impact that changes in prices or changes in volume of products being sold has on the change in net sales from period to period. We are able to estimate these impacts at a higher level and propose revisions to
disclose the quantification of factors to which changes can be attributed in future filings beginning with the Form 10-Q for the quarterly period ended June 30, 2023.

For illustrative purposes, below is the Company’s proposed disclosure using the above-referenced 2022 Form
10-K as a model. Revisions have been marked to facilitate the Staff’s review. The Company will endeavor to provide similar levels of disclosure in future filings.

Net Sales

Net sales were $21.4 billion for 2022 compared with $18.2 billion for 2021, an increase of 17.6%. The
increase primarily reflects price inflation, and volume
growth,
and secular demand trends,
which resulted in a mid-teens percentage increase. and Additionally, execution of our cross-sell program impacted net sales by a low single digit percentage. Organic sales for 2022 grew 18.2% as the acquisition of Rahi Systems in the fourth quarter of 2022, partially offset by the divestiture of Wesco’s legacy utility and data communications businesses in Canada
in the first quarter of 2021, positively impacted reported net sales by 0.5%. Additionally, the number of workdays positively impacted reported net sales by 0.4%, while fluctuations in foreign exchange rates negatively impacted reported net sales by
1.5%. All segments reported double-digit sales growth versus the prior year, as discussed below. For the year ended December 31, 2022, pricing related to inflation favorably impacted our net sales by approximately 8%.

EES reported net sales of $8.8 billion for 2022 compared to $7.6 billion for 2021, an increase of
15.8%. Organic sales for 2022 grew 17.3% as the number of workdays positively impacted reported net sales by 0.4%, while fluctuations in foreign exchange rates and the Canadian divestitures described in our overall results above negatively impacted
reported net sales by 1.8% and 0.1%, respectively. The year-over-year increase in organic sales reflects price inflation, market growth in our industrial, construction, and original equipment manufacturer businesses, as

 5

well as secular growth trends which impacted net sales by a mid-teens percentage. as well as Additionally, the benefits of cross selling
and secular growth trends impacted net sales by a low single digit percentage. Additionally, supply chain constraints have had a negative impact on
sales in both 2022 and 2021; however, these pressures have begun to moderate.

 CSS reported net
sales of $6.4 billion for 2022 compared to $5.7 billion for 2021, an increase of 12.0%. Organic sales for 2022 grew 11.5% as the acquisition of Rahi Systems in the fourth quarter of 2022 and the number of workdays positively impacted
reported net sales by 2.0% and 0.4%, respectively, while fluctuations in foreign exchange rates negatively impacted reported net sales by 1.9%. The year-over-year increase in organic sales reflects price inflation and strong
market growth in our security solutions and network infrastructure businesses, which impacted net sales by a mid-single digit percentage. as well as The benefits of cross selling also impacted net sales by a low single digit percentage and some improvements in supply chain constraints had a less significant impact on net sales.

 UBS reported net sales of $6.2 billion for 2022 compared
to $4.9 billion for 2021, an increase of 26.9%. Organic sales for 2022 grew 27.2% as the number of workdays positively impacted reported net sales by 0.4%, while fluctuations in foreign exchange rates and the Canadian divestitures described in
our overall results above negatively impacted reported net sales by 0.6% and 0.1%, respectively. The year-over-year increase in organic sales reflects price inflation, broad-based market growth driven by investments in electrification, green energy, utility grid modernization and hardening, and rural
broadband development, as well as expansion in our integrated supply business which resulted in a high teens percentage increase in net sales. The benefits of cross selling also impacted net sales by a mid single digit percentage.

 Consolidated Statements of Stockholders’ Equity, page 49

Comment No. 4:

 Please revise to include a
column for total stockholders’ equity.

 Response:

The Company respectfully acknowledges the Staff’s comment and advises that we will include a column for total stockholders’ equity in any future
filings in which we include a Consolidated Statement of Stockholders’ Equity, beginning with the Form 10-Q for the quarterly period ended June 30, 2023.

For illustrative purposes, refer to Exhibit A for the Company’s proposed disclosure using the above-referenced 2022 Form 10-K. Revisions have been marked to facilitate the Staff’s review.

 6

 Note 2. Accounting Policies

Revenue Recognition, page 51

 Comment
No. 5:

 Your disclosure includes your accounting policy for the prov