July 10, 2024

Samantha Stoddard
Executive Vice President and Chief Financial Officer
JELD-WEN Holding, Inc.
2645 Silver Crescent Drive
Charlotte, NC 28273

       Re: JELD-WEN Holding, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 8-K filed February 20, 2024
           Form 8-K filed May 6, 2024
           File No. 001-38000
Dear Samantha Stoddard:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Forms 8-K Filed February 20, 2024 and May 6, 2024
Exhibit 99.1

1.     We note you present non-GAAP financial measures that include an
adjustment for "net
       legal and professional expenses and settlements   . For each of the two
most recent fiscal
       years and the subsequent interim period, including the comparable
interim period, please
       tell us the specific nature and amount of the legal expenses,
professional expenses, and
       settlements included in your non-GAAP adjustments. Explain the specific
nature of the
       strategic transformation expenses, that you indicate are primarily
third-party advisory
       fees, including the services provided to date and the services expected
to be continued to
       be provided. Also, explain how you determined each expense included in
your non-GAAP
       adjustment does not represent a normal operating expense necessary to
operate your
       business and is consistent with the guidance in Question 100.01 of the
Division of
       Corporation Finance's Compliance & Disclosure Interpretations on
Non-GAAP Financial
       Measures.
 July 10, 2024
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.

       Please contact Jeffrey Gordon at 202-551-3866 or Anne McConnell at
202-551-3709
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing