April 25, 2019

John Sznewajs
Chief Financial Officer
MASCO CORP /DE/
17450 College Parkway
Livonia, MI 48152

       Re: MASCO CORP /DE/
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 7, 2019
           File No. 001-05794

Dear Mr. Sznewajs:

       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 10-K for Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Cash Flows, page 22

1.    We note your "Accounts Payable days" are 71 days as of December 31, 2018.
We further
      note your Accounts Payable days has increased substantially over the past
ten years, with
      a low of 47 days in 2009, followed by a substantial increase to 63 days
in 2011. Please
      tell us if you are engaging in supply chain finance operations and
mechanisms, such as
      reverse factoring or similar methods to increase your Accounts Payable
days. Otherwise,
      please explain how you have been able to achieve such extended accounts
payable terms
      with your suppliers.
 John Sznewajs
MASCO CORP /DE/
April 25, 2019
Page 2




       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 Kevin Stertzel at (202) 551-3723 with any questions.



                                                           Sincerely,
FirstName LastNameJohn Sznewajs
                                                           Division of
Corporation Finance
Comapany NameMASCO CORP /DE/
                                                           Office of
Manufacturing and
April 25, 2019 Page 2                                      Construction
FirstName LastName