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April 8, 2024
Todd Fister
Chief Financial Officer
Owens Corning
One Owens Corning Parkway
Toledo, OH 43659
Re:Owens Corning
Form 10-K for the year ended December 31, 2023
Form 8-K filed on February 14, 2024
File No. 001-33100
Dear Todd Fister:
            We have limited our review of your filings to the financial statements and related
disclosures 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.
Form 8-K filed on February 14, 2024
Exhibit 99.1
1.We note you present Adjusted EBIT Margin and Adjusted EBITDA Margin but you do
not present the most directly comparable GAAP measure, Net Earnings Margin, with
equal or greater prominence. For each non-GAAP financial measure you present, please
present the most directly comparable GAAP measure with equal or greater prominence as
required by Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Division of
Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.

2.You indicate in Table 7 that the adjusting items under (a) in the reconciliations for
Adjusted Earnings and Adjusted Diluted Earnings Per Share are included in Table 2;
however, we note the adjusting items in Table 2 are not provided for each period you
present Adjusted Earnings and Adjusted Diluted Earnings Per Share in Table 7. Please
ensure all non-GAAP adjustments are appropriately provided for all periods presented.

 FirstName LastNameTodd  Fister
 Comapany NameOwens Corning
 April 8, 2024 Page 2
 FirstName LastName
Todd  Fister
Owens Corning
April 8, 2024
Page 2

3.We note you present Free Cash Flow Conversion in Table 8 but you do clearly identify it
as a non-GAAP financial measure or present the most directly comparable GAAP
measure, based on Net Earnings rather than Adjusted Earnings, with equal or greater
prominence. For each non-GAAP financial measure you present, please properly title the
measure and present the most directly comparable GAAP measure with equal or greater
prominence as required by Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of
the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-
GAAP Financial Measures.

Form 10-K for the year ended December 31, 2023
Consolidated Financial Statements
16. Contingent Liabilities and Other Matters, page 105
4.In the first paragraph, we note you disclose “management believes that the amount of any
reasonably possible losses in excess of any amounts accrued, if any, with respect to such
Proceedings or any other known claim, including the matters described below under the
caption Environmental Matters (the “Environmental Matters”), are not material to the
Company’s financial statements”; however, in the last sentence of the third paragraph, you
disclose “it is reasonably possible that additional product recall costs could be incurred
that exceed the estimated liability by amounts that could be material to our consolidated
financial statements”. These disclosures appear inconsistent and potentially confusing.
Please correct the inconsistency. In addition, to the extent you believe it is reasonably
possible that losses exceeding amounts accrued could be material to your consolidated
financial statements, provide a range for such losses or, if applicable, disclose a range
cannot be provided and explain the nature, extent, and timing of the additional information
that is required for you to provide an estimated loss range.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact SiSi Cheng at 202-551-5004 or Anne McConnell at 202-551-3709 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing