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SEC Comment Letter for Atkore (ATKR) — Feb 23, 2017

Atkore Inc.
Date: Feb. 23, 2017 · CIK: 0001666138 · Accession: 0000000000-17-006233

AI Filing Summary & Sentiment

File numbers found in text: 001-37793

Date
February 23, 2017
Author
/s/Gary Todd for
Form
UPLOAD
Company
Atkore Inc.

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANC E Mail Stop 3030 February 23, 2017 Via E -mail Mr. James A. Mallak Vice President and Chief Financial Officer Atkore International Group Inc. 16100 South Lathrop Avenue Harvey, Illinois 60426

Re: Atkore International Group Inc. Form 10-K for the Fiscal Year Ended September 30, 2016 Filed November 29, 2016 Form 10 -Q for the Quarter ly Period Ended December 30, 2016 Filed February 7, 2017 File No . 001-37793

Dear Mr. Mallak :

We have limited our review of your filing to the financial statements and related disclosures and have the following comment . 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 comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.

Form 10 -Q for the Quarter ly Period Ended December 30, 2016

Exhibits 31.1 and 31.2

1. We see that the officer certifications do not include the language referring to internal control over financial reporting that should appear in the introductory sentence of paragraph 4. Please amend the filing to include the correct certifications. You may file an abbreviated amendment that includes a cover page, explanatory note, signature page and paragraphs 1, 2, 4 and 5 of the certification. Refer to Exchange Act Rule 13a-14(a) and Item 601(b)(31) of Regulation S-K.

Mr. James A. Mallak Atkore International Group Inc. February 23, 2017 Page 2

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.

You may contact Jeanne Bennett at (202) 551 -3606 or Gary Todd, Senior Accountant , at (202) 551 -3605 with any questions. You may also reach me at (202) 551 -3676.

Sincerely,
/s/Gary Todd for

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANC E
Mail Stop 3030
February 23, 2017

Via E -mail
Mr. James A. Mallak
Vice President and Chief  Financial Officer
Atkore International Group Inc.
16100 South Lathrop Avenue
Harvey, Illinois 60426

 Re: Atkore International Group Inc.
Form 10-K for the Fiscal Year Ended  September 30, 2016
Filed November 29, 2016
Form 10 -Q for the Quarter ly Period  Ended December 30, 2016
Filed February 7, 2017
File No .  001-37793

Dear Mr. Mallak :

We have limited our review of your filing to the financial statements and related
disclosures and have the following comment .  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 comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If  you do not believe our
comment applies  to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment , we may have  additional comments.

Form 10 -Q for the Quarter ly Period  Ended December 30, 2016

Exhibits  31.1 and 31.2

1. We see that the officer  certifications  do not include  the language referring  to internal
control  over financial  reporting  that should appear  in the  introductory  sentence  of
paragraph  4.  Please  amend  the filing  to include  the correct  certifications.   You may  file
an abbreviated  amendment  that includes  a cover  page,  explanatory  note, signature  page
and paragraphs  1, 2, 4 and 5 of the certification.  Refer  to Exchange Act Rule 13a-14(a)
and Item 601(b)(31) of  Regulation  S-K.

Mr. James A. Mallak
Atkore  International Group Inc.
February 23, 2017
Page 2

 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.

You may contact Jeanne Bennett  at (202) 551 -3606 or Gary Todd, Senior Accountant , at
(202) 551 -3605  with any questions.   You may also reach me at (202) 551 -3676.

Sincerely,

 /s/Gary Todd for

 Brian Cascio
 Accounting Branch Chief