November 25, 2019 Brian G. Harris Chief Financial Officer Griffon Corporation 712 Fifth Ave, 18th Floor New York, NY 10019 Re: Griffon Corporation Form 10-K for the year ended September 30, 2018 Filed November 19, 2018 File No. 1-6620 Dear Mr. Harris: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Manufacturing