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 March 10, 2026

John M. Deitzer
Chief Financial Officer
Atkore Inc.
16100 South Lathrop Avenue
Harvey, Illinois 60426

 Re: Atkore Inc.
 Form 10-K for the Year Ended September 30, 2025
 Filed November 26, 2025
 File No. 001-37793
Dear John M. Deitzer:

 We have limited our review of your filing 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 10-K for the Year Ended September 30, 2025
Management s Discussion and Analysis of Financial Condition and Results of
Operations
Business Factors Influencing our Results of Operations, page 37

1. We note the discussion of economic conditions influencing your
operations beginning on
 page 37. You indicate that you generally sell your products on a spot
basis and as such,
 were exposed to sales prices on your products that decreased faster than
the cost of the
 related raw materials. We further note the analysis of segment results
indicates the
 Electrical segment's average selling price decreased while its input
costs increased and
 the Safety & Infrastructure segment's input costs decreased faster than
its selling prices
 decreased, both of which seem somewhat different from the statement on
page 37. Please
 explain to us in more detail the meaning of the disclosure on page 37
and how it relates
 to the explanation of changes in segment profitability, and revise
future filings to clarify
 these matters to your investors. Please ensure readers can easily
understand how the
 discussion of trends at the beginning of your MD&A relates to the
discussion of trends
 within the more detailed analysis of results. Refer to Item 303 of
Regulation S-K and
 SEC Release No. 33-8350 for guidance.
 March 10, 2026
Page 2

Critical Accounting Estimates
Indefinite-Lived Intangible Assets and Goodwill Impairments, page 50

2. We note your disclosure that in fiscal 2025 you performed a quantitative
impairment
 assessment for goodwill for your six reporting units. You recorded a
goodwill
 impairment on the Mechanical reporting unit of $18.9 million as a result
of this annual
 impairment test. You also indicated that the fair values of the Conduit
& Fittings and
 EMEA reporting units exceed their respective carrying value, but changes
in your
 valuation assumptions could have resulted in an impairment. However, you
do not
 discuss the results of the remaining three reporting units. Please
expand your critical
 accounting estimates disclosure to indicate whether the fair value
substantially exceeds
 book value for all reporting units at the date of your most recent
impairment test. If the
 fair value substantially exceeded book value for all reporting units,
please disclose such
 information to your readers as we believe it provides them with valuable
information in
 assessing the sensitivity of your goodwill to future impairment.
Alternatively, if the fair
 value of any reporting unit does not substantially exceed book value,
identify the
 reporting unit and disclose the following:
 the percentage by which fair value exceeded carrying value at the
date of the most
 recent test;
 the amount of goodwill allocated to the reporting unit;
 a detailed description of the methods and key assumptions used and
how the key
 assumptions were determined;
 a discussion of the degree of uncertainty associated with the
assumptions; and
 a description of potential events and/or changes in circumstances
that could
 reasonably be expected to negatively affect the key assumptions.
 Please include these expanded disclosures in future filings and provide
us with your
 proposed disclosure as part of your response. Refer to Item 303(b)(3) of
Regulation S-K
 and Section V of SEC Release No. 33-8350 for guidance.
 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 Ernest Greene at 202-551-3733 or Jennifer Thompson at
202-551-3737
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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