October 25, 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 333-137249-01)

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 26, 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