November 8, 2019

Craig Kesler
Chief Financial Officer
EAGLE MATERIALS INC
5960 Berkshire Lane, Suite 900
Dallas, TX 75225

       Re: EAGLE MATERIALS INC
           Form 10-K for the year ended March 31, 2019
           Filed May 23, 2019
           Form 8-K filed July 30, 2019
           File No. 1-12984

Dear Mr. Kesler:

       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 the Year Ended March 31, 2019

Consolidated Financial Statements
(A) Significant Accounting Policies
Impairment or Disposal of Long-Lived and Intangible Assets, page 73

1.    We note your disclosures related to the material impairment charge you
recorded during
      the year ended March 31, 2019. Please expand your disclosures to more
fully address the
      following:
        Describe the specific assets or asset groups that you tested for
impairment and that
           were impaired;
        Disclose the carrying values of the assets you tested for impairment
and the
           remaining carrying values of the assets that were impaired; and
        To the extent material, disclose and discuss the risks and
uncertainties related to any
           reasonably possible asset impairments expected in the next 12
months. Specifically
 Craig Kesler
EAGLE MATERIALS INC
November 8, 2019
Page 2
             address the nature of the identifiable assets in the oil and gas
proppants segment,
             including the nature of the material capital expenditures related
to this segment
             incurred during the last two fiscal years.
         Refer to ASC 360-10-50-2, ASC 820-10-50-2, ASC 820-10-55-100, and ASC
275-10-50-
         8.
Form 8-K Filed on July 30, 2019

Exhibit 99.1, page 10

2.       We note your presentation of non-GAAP adjustments you use to calculate
the non-GAAP
         financial measure, Adjusted Earnings per Diluted Share. Adding back
adjustments, net of
         tax, is not consistent with the guidance provided in Question 102.11
of the the updated
         Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures (April 4,
         2018). Please revise your future non-GAAP presentations accordingly.

       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 Mindy Hooker at (202) 551-3732 or Anne McConnell at (202)
551-
3709 with any questions.



FirstName LastNameCraig Kesler                              Sincerely,
Comapany NameEAGLE MATERIALS INC
                                                            Division of
Corporation Finance
November 8, 2019 Page 2                                     Office of
Manufacturing
FirstName LastName