TEXT-EXTRACT 2 filename2.txt March 22, 2019 Matthew Marsh Chief Financial Officer James Hardie Industries plc Europa House, Second Floor, Harcourt Centre Harcourt Street, Dublin 2, Ireland Re: James Hardie Industries plc Form 20-F for the Year Ended March 31, 2018 Filed May 22, 2018 File No. 001-15240 Dear Mr. Marsh: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Year Ended March 31, 2018 Consolidated Financial Statements 14. Income Taxes, page 145 1. We note your disclosures related to the adoption of ASU 2016-16. Please more fully address the following: Clarify the nature of the internal restructuring you undertook to align certain intangible assets; Disclose how you determined the amount of the related tax valuation allowance you recorded; and To the extent your realization of net deferred tax assets is subject to material assumptions and estimates, revise your critical accounting policies to disclose and discuss the assumptions and estimates, including, if applicable, the jurisdictions to which they relate. Matthew Marsh James Hardie Industries plc March 22, 2019 Page 2 17. Operating Segment Information and Concentration of Risk, page 153 2. Please revise your geographic disclosures to present net sales and identifiable assets related to the U.S. as required by ASC 280-10-50-41. To the extent that substantially all the amounts disclosed for North America relate to the U.S., please clarify that fact. 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. You may contact Ernest Greene, Staff Accountant at 202-551-3733 or Anne McConnell, Staff Accountant at 202-551-3709 with any questions. Sincerely, FirstName LastNameMatthew Marsh Division of Corporation Finance Comapany NameJames Hardie Industries plc Office of Manufacturing and March 22, 2019 Page 2 Construction FirstName LastName