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CORRESP
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CORRESP

 April 15, 2016

 Russell
Mancuso

 Branch Chief

 Office of Electronics and Machinery

 U.S. Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

Re:
Atkore International Group Inc.

 Registration Statement on Form S-1

Filed March 4, 2016

File No. 333-209940

 Dear Mr. Mancuso:

 This letter sets forth the responses of Atkore International Group Inc. (the “Registrant”) to the comments contained in
your letter, dated March 31, 2016, relating to the Registration Statement on Form S-1, File No. 333-209940, filed by the Registrant on March 4, 2016 (the “Registration Statement”). The comments of the staff of the U.S. Securities
and Exchange Commission (the “Staff”) are set forth in bold italicized text below, and the responses of the Registrant are set forth in plain text immediately following each comment.

The Registrant is submitting, via EDGAR, Amendment No. 1 to the Registration Statement (“Amendment No. 1”). Enclosed with the
paper copy of this letter are four copies of a clean version of Amendment No. 1, as well as four copies of a blacklined version of Amendment No. 1, marked to show changes from the Registration Statement filed on March 4, 2016. Page
references in the responses below are to Amendment No. 1.

 Market and Industry Data, page ii

1. Please tell us whether you commissioned any of the third-party data that you disclose in your registration statement.

 The Registrant advises the Staff that no data disclosed in the Registration Statement as having been prepared by a third party
have been commissioned by the Registrant.

Russell Mancuso

 2

April 15, 2016

 Prospectus Summary, page 1

2. We refer to the charts on pages 1 and 75, as well as other disclosures of adjusted net sales appearing in
your prospectus summary and repeated in the business section of your document. Please revise the disclosures to present and discuss net sales determined according to GAAP with equal or greater prominence. Refer to Item 10(e)(1)(i) of
Regulation S-K.

 In response to the Staff’s comment, the Registrant has revised and provided additional disclosure on pages
1, 3, 80 and 82.

 3. In the bullet points on page 2 of the prospectus summary and on page 76 of the
business section of your document you present statistical measures of compound annual growth of adjusted EBITDA and expansion of EBITDA margin. Tell us why it is appropriate to present these statistical measures absent also presenting
comparable statistical measures calculated using GAAP numerators and denominators with equal or greater prominence.

 In response
to the Staff’s comment, the Registrant has provided additional disclosure on pages 2, 6, 80 and 85.

4. We refer to the chart on page 3 of the prospectus summary and on page 78 of the business section of your
document. We see that you have presented measures of segment adjusted EBITDA and adjusted EBITDA margin for the twelve months ended December 31, 2015. Tell us how your disclosure of these measures is appropriate under Item 10(e) of
Regulation S-K or revise appropriately. In this regard, it is unclear how the measures of segment adjusted EBITDA can be reconciled to the ASC 280 information presented in your financial statements or the income statement you elected to present
for the twelve months ended December 31, 2015.

 In response to the Staff’s comment, the Registrant has provided additional
disclosure on pages 3, 16, 82, F-42 and F-66. The Registrant further advises the Staff that it has provided a reconciliation of Adjusted EBITDA by segment for the twelve months ended December 31, 2015 on page 16, derived from the ASC 280 information
for the three month periods ended December 25, 2015 and December 26, 2014, respectively disclosed on pages F-66, and for the fiscal year ended September 25, 2015 disclosed on page F-42.

The Registrant’s Chief Operating Decision Maker uses Adjusted EBITDA as the segment primary measure of profit and loss, as permitted by
ASC 280, which allows a company to determine segment profitability on a basis that differs from the amounts in the consolidated financial statements determined in accordance with GAAP. As clarified by Non-GAAP Financial Measures Compliance and
Disclosure Interpretation 104.01, segment information that is presented in conformity with ASC 280 is not considered to be a non-GAAP financial measure under Item 10(e) of Regulation S-K.

Russell Mancuso

 3

April 15, 2016

 The Registrant presents segment Adjusted EBITDA margin calculated as segment Adjusted EBITDA
as a percentage of Adjusted net sales. In order to comply with Item 10(e) of Regulation S-K, the Registrant has provided additional disclosure on pages 3 and 82 to also present, with equal or greater prominence, the most directly comparable
financial measure calculated and presented in accordance with GAAP, which is Adjusted EBITDA margin calculated as segment Adjusted EBITDA as a percentage of net sales (such term is calculable from two GAAP terms, and, consistent with Item
10(e)(4)(ii) of Regulation S-K, is not a non-GAAP measure).

 5. We refer to the disclosure of the cash flow conversion
percentage, appearing under the heading “Strong margin and cash flow profile” on pages 6 and 81 of your document. We note that this statistical measure is derived in part from adjusted EBITDA, a non-GAAP measure. Tell us why it is
appropriate to present this statistical measure absent also presenting a comparable statistical measure calculated using amounts that are not non-GAAP measures. Also, tell us how disclosure about this ratio is complete under Item 10(e) of Regulation
S-K.

 In response to the Staff’s comment, the Registrant has removed the reference to cash flow conversion on pages 6 and 85.

 Our Sponsor, page 8

6. We note your disclosure highlighting $21 billion in 65 businesses and more than $100 billion. Please tell us whether all
of these businesses became “more profitable” during the period of your sponsor’s investment, whether those business and transactions generated any losses for investors, and whether your sponsor controlled each business. Also tell us
the criteria you used to determine which investments to highlight in the last sentence of the first paragraph of this section; include in your response whether any unnamed investments also satisfy those criteria.

In response to the Staff’s comment, the Registrant has revised the disclosure on page 8. The Registrant also notes that the investments
by Clayton, Dubilier & Rice, LLC (“CD&R”) highlighted in the last sentence of the first paragraph of this section represent all equity investments by CD&R in the industrial and construction markets in the last decade.

 Selected Historical Consolidated Financial Information, page 44

7. We see that you have elected to present an income statement for the twelve months ended December 31, 2015. Please
add comparative disclosures for the twelve months ended December 31, 2014. Also, expand MD&A to discuss the twelve month periods ended December 31. Refer to Item 303(b)(2) of Regulation S-K.

In response to the Staff’s comment, the Registrant has provided additional disclosure starting on page 53.

Russell Mancuso

 4

April 15, 2016

 Management’s Discussion and Analysis, page 48

8. We note your reference on page 1 to providing services. Please tell us the extent of your business derived from
these services.

 The Registrant advises the Staff that it provides specialty contracting services under its Unistrut Construction
brand name to design, construct and install turn-key framing solutions that address complex construction needs of its customers. In fiscal 2015, sales derived from services performed by Unistrut Construction were approximately $39
million. The Registrant considers these services to be ancillary in nature and immaterial to its business.

 Business Factors Influencing
Results of Operations, page 48

 9. If the Flexhead Industries acquisition that you disclose in the second
paragraph on page 50 is part of your Fence and Sprinkler product line that you exited in 2015, please revise your disclosure to clarify.

The Registrant advises the Staff that FlexHead Industries was not part of the Registrant’s Fence and Sprinkler product line that the
Registrant exited in the first quarter of fiscal 2016.

 Industry Trends, page 49

10. Please tell us the portion of your business derived from the solar power generation industry. Also tell us whether
more current growth-rate data materially differs from the disclosed rate.

 The Registrant advises the Staff that the
Registrant’s total sales derived from the solar power generation industry are difficult to quantify since such sales are made through a variety of sources, including through third-party distributors. In fiscal 2015, the Registrant’s sales
of its mechanical tube products to solar original equipment manufacturers were approximately $66 million, or 4.3% and 3.8%, of the Registrant’s adjusted net sales and net sales, respectively. Further, in response to the Staff’s comment,
the Registrant has removed the U.S. Energy Information Administration’s forecasted solar photovoltaic power generation compound annual growth rate from page 49.

Net Sales, page 53

11. Please disclose the reasons for the decrease in volume of products sold mentioned in this paragraph, the first
paragraph on page 55, and the last full paragraph on page 56.

 In response to the Staff’s comment, the Registrant has
provided additional disclosure on pages 57, 58 and 60.

Russell Mancuso

 5

April 15, 2016

 Cost of Sales, page 53

12. Please separately and clearly discuss (1) the extent of the impact of material costs and (2) the extent of the impact
of volume changes on your cost of sales.

 In response to the Staff’s comment, the Registrant has provided additional
disclosure on page 57.

 Asset Impairment, page 57

13. Please disclose the reasons for the decrease in sales of the higher-margin product to the key customer.

In response to the Staff’s comment, the Registrant has provided additional disclosure on page 61.

Critical Accounting Policies and Use of Estimates, page 65

Revenue Recognition, page 65

14. We reference the disclosure that you make provisions for sales incentives, trade promotions, product returns, and
discounts based on estimates using historical experience and trend analysis. Please provide additional disclosure about the nature of each of the incentives and promotions provided to customers and specific trends that you use in estimating
provisions.

 The Registrant advises the Staff that it does not have significant sales incentives and trade promotions other than
customer rebates, which are based on sales volumes. In response to the Staff’s comment, the Registrant has revised the revenue recognition critical accounting policy on page 70 to refer to customer rebates, product returns and discounts only,
and to disclose further information regarding the nature of its rebates and the information used in estimating provisions for product returns and discounts.

Stock-Based Compensation, page 68

15. Please tell us the estimated IPO price range once you have that information. To the extent there is a significant
difference between the estimated grant-date fair value of your common shares during the past twelve months and the estimated IPO price range, please discuss for us each significant factor contributing to the difference.

The Registrant acknowledges the Staff’s comment and will disclose the estimated IPO price range once such information is available.

Russell Mancuso

 6

April 15, 2016

 Contractual Obligations, page 72

16. Please revise to disclose in a footnote to the contractual obligations table the nature of the purchase commitments.

 In response to the Staff’s comment, the Registrant has provided additional disclosure on page 77.

Our Reportable Segments, page 76

17. Please tell us whether each of the markets and applications mentioned in the last sentence of the second and fifth
paragraphs of this section contribute equally to your business. If not, please tell us the criteria you used to determine which markets and applications to identify. Also tell us whether other markets or applications contribute to your
business to the same or a greater extent.

 The Registrant advises the Staff that each of the end markets and applications
mentioned in the last sentence of the second and fifth paragraphs of the Registration Statement does not contribute equally to its business. Rather, these end markets and applications are not material to the business and represent end markets and
applications for only a subset of the Registrant’s products. As a result, the Registrant has revised the disclosure on page 81 to remove references to these end markets and applications.

18. Please tell us whether wither [sic] your metal framing business or your mechanical tubular products
business accounted for 10 percent or more of your consolidated revenue in any of the last three fiscal years. See Regulation S-K item 101(c)(1)(i). In this regard, please tell us how these businesses are consistent with the business
mentioned in the last column of the table on page 91.

 The Registrant advises the Staff that each of its metal framing and
mechanical tubular products accounted for more than 10 percent of the Registrant’s consolidated revenue in each of its last three fiscal years. In response to the Staff’s comment, the Registrant has provided additional disclosure on page
89.

 The Registrant further advises the Staff that the product categories listed on pages 88 and 89 do not represent businesses, rather,
they are product lines. Mr. Waltz, Vice President and President, Conduit & Fittings, is responsible for the management of the first three product categories listed in the chart on page 88, Mr. Lariviere, Vice President and President, Cable
Solutions, is responsible for the management of the next two product categories listed on pages 88 and 89, and Mr. Schulte, Vice President and President, Mechanical Products & Solutions, is responsible for the last five product categories listed
on page 89.

 Intellectual Property, page 87

19. We note your reference to patents relating to “a range” of your products. If not all of your material
products include patented technology, please revise to clarify the scope of your products that include such technology.

 In
response to the Staff’s comment, the Registrant has revised its disclosure on page 92 to remove the reference to the number of current and pending patents, since as noted on page 92, the Registrant does not believe its competitive position is
dependent on patent or trademark protection or that its operations are dependent on any single patent or group of related patents.

Russell Mancuso

 7

April 15, 2016

 20. Please reconcile the last sentence of the first full risk factor on page 25 with
your disclosure in this last paragraph of this section.

 In response to the Staff’s comment, the Registrant has
revised the disclosure on page 92.

 Legal Proceedings, page 90

21. It appears that you have selected one of the lawsuits mentioned in the second paragraph to name and to identify the court in which
the proceedings were instituted and the date instituted. Please tell us how you selected which matter to so disclose, and provide us your analysis of how disclosing only one such matter is consistent with Regulation S-K Item 103. Also,
disclose the relief sought in the proceedings.

 The Registrant advises the Staff that it is not currently party to
any legal proceeding that would require disclosure under Regulation S-K Item 103. Nonetheless, the Registrant has elected to voluntarily disclose the Wind Condominium Association, Inc., et al putative class action given the broad and undefined
nature of the relief sought and the potential size of the alleged class. In response to the Staff’s comment,