March 18, 2020 Seth L. Kaplan Senior Vice President, General Counsel and Secretary Griffon Corporation 712 Fifth Avenue, 18th Floor New York, New York 10019 Re: Griffon Corporation Registration Statement on Form S-4 Filed March 13, 2020 File No. 333-237166 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 Thomas Jones at 202-551-3602 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Martin Nussbaum