CORRESP 1 filename1.txt GIBRALTAR INDUSTRIES, INC. 3356 LAKE SHORE ROAD P.O. BOX 2028 BUFFALO, NY 14219 August 8, 2006 BY EDGAR AND BY FAX Securities and Exchange Commission Station Place 100 F Street, NE Washington, DC 20549 Attention: Assistant Director Division of Corporation Finance Re: Gibraltar Industries, Inc. Gibraltar Strip Steel, Inc. Air Vent Inc. GSCNY Corp. Alabama Metal Industries Corporation Gibraltar of Michigan, Inc. Appleton Supply Company, Inc. Gibraltar of Indiana, Inc. 3073819 Nova Scotia Company HT Liquidating Corp. Former Leasing Liquidating, LLC International Grating, Inc. Former Heat Treat Liquidating, Corp. K&W Metal Fabricators, LLC BC Liquidating Corp. Gibraltar of Pennsylvania, Inc. Gibraltar of Nevada, Inc. SCM Metal Products, Inc. Cleveland Pickling, Inc. Sea Safe, Inc. Construction Metals, LLC Solar Group, Inc. Diamond Perforated Metals, Inc. Solar of Michigan, Inc. Gator Grate, Inc. Southeastern Metals Manufacturing Inc. Gibraltar International, Inc. United Steel Products Company, Inc. Gibraltar Steel Corporation of WM. R. Hubbell Steel Corporation New York Registration Statement on Form S-4 Registration No. 333-135908 ---------------------------------- Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the "Act"), the undersigned Registrant and Co-Registrants hereby request acceleration of the effective date of the above-referenced Registration Statement on Form S-4 (the "Registration Statement") to 5:00 p.m., Eastern time, on August 8, 2006 or as soon thereafter as practicable. We acknowledge that should the Securities and Exchange Commission (the "Commission") or the staff acting by delegated authority declare the Registration Statement effective, (i) it does not foreclose the Commission from taking any action on the Registration Statement, and (ii) it does not relieve us from our full responsibility for the adequacy and accuracy of the Registration Statement's disclosure. We further acknowledge that we may not assert the Commission's or staff's comments and the declaration of the Registration Statement's effectiveness as a defense in any proceedings initiated by the Commission or any person under the United States' federal securities laws. We confirm our awareness of our statutory responsibilities under the Act and the Securities Exchange Act of 1934, as amended. Please notify Michael E. Storck, Esq. of Lippes Mathias Wexler Friedman LLP, counsel to the Registrant and Co-Registrants, at (716) 853-5100, as soon as possible as to the time the Registration Statement has been declared effective pursuant to this acceleration request or if you require additional information. Very truly yours, GIBRALTAR INDUSTRIES, INC., and each of the co-registrants listed above By: /S/ David W. Kay ----------------------------------------- Name: David W. Kay Title: Executive Vice President, Chief Financial Officer and Treasurer