October 18, 2006

Securities and Exchange Commission
Washington, DC 20549

            RE:   GRAYBAR ELECTRIC COMPANY, INC. AND VOTING TRUSTEES UNDER
                  VOTING TRUST AGREEMENT
                  REGISTRATION STATEMENT ON FORM S-1
                  (REGISTRATION NOS. 333-137249 AND 333-138035)

Gentlemen:

            Pursuant to Rule 461 promulgated under the Securities Act of 1933,
as amended, Graybar Electric Company, Inc. and the Voting Trustees under the
Voting Trust Agreement, dated as of April 1, 1997, relating to Common Stock
issued by Graybar Electric Company, Inc. hereby request acceleration of the
effective date of the above-captioned Registration Statement so that it may
become effective at 9:00 a.m. on October 23, 2006, or as soon thereafter as
practicable.

            The Company and the Voting Trustees acknowledge that (i) should
the Commission or the staff, acting pursuant to delegated authority, declare
the Registration Statement effective, it does not foreclose the Commission
from taking any action with respect to the filing, (ii) the action of the
Commission or the staff, acting pursuant to delegated authority, in declaring
the Registration Statement effective, does not relieve the Company or the
Voting Trustees from their full responsibility for the adequacy and accuracy
of the disclosure in the




filing, and (iii) the Company and the Voting Trustees may not assert staff
comments and the declaration of effectiveness as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.


                                      Sincerely,

                                      GRAYBAR ELECTRIC COMPANY, INC.


                                      By:  /s/ T. F. Dowd
                                           -----------------------------------
                                           T. F. Dowd, Senior Vice President,
                                           Secretary and General Counsel

                                      VOTING TRUSTEES


                                      /s/ R. A. Reynolds, Jr.
                                      ----------------------------------------
                                      R. A. Reynolds, Jr.

                                      /s/ D. E. DeSousa
                                      ----------------------------------------
                                      D. E. DeSousa

                                      /s/ L. R. Giglio
                                      ----------------------------------------
                                      L. R. Giglio

                                      /s/ T. S. Gurganous
                                      ----------------------------------------
                                      T. S. Gurganous

                                      /s/ R. D. Offenbacher
                                      ----------------------------------------
                                      R. D. Offenbacher