September 16, 2008

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: Angela Crane and Julie Sherman

Re:	Graybar Electric Company, Inc.
	Form 10-K for the fiscal year ended December 31, 2007
	File No. 000-00255

Ladies and Gentlemen:

On behalf of Graybar Electric Company, Inc., I am transmitting with this letter

Amendment No. 2 to the above-referenced filing following previous correspondence and

telephone conversations between members of the Staff and our outside counsel, James R.

Levey of Bryan Cave LLP.

We appreciate the Staff’s review. If you require any additional information regarding

this matter, or if you require any other information that would facilitate the completion of

your review of this filing, please advise Mr. Levey at your earliest convenience. You

may reach Mr. Levey at 314-259-2296, or by fax at 314-552-8296. You may also contact

me at 314-573-9278, or by fax at 314-573-9445.

Very truly yours,

/s/ MATTHEW W. GEEKIE

Matthew W. Geekie

MWG/cg

Enclosure

cc:	Mr. D. Beatty D’Alessandro, Senior Vice President and Chief Financial Officer,
	Graybar Electric Company, Inc.
	Mr. Martin J. Beagen, Vice President and Controller, Graybar Electric Company, Inc.
	Alice W. Lehnhoff, Esq., Corporate Counsel, Graybar Electric Company, Inc.
	James R. Levey, Esq., Partner, Bryan Cave LLP