TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo June 29, 2020 Seth L. Kaplan Senior Vice President, General Counsel, and Secretary Griffon Corporation 725 Fifth Avenue, 18th Floor New York, NY 10019 Re: Griffon Corporation Registration Statement on Form S-4 Filed June 23, 2020 File No. 333-239373 Dear Mr. Kaplan: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Martin Nussbaum, Esq.