November 22, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attention: David Gessert

Re: Arthur J. Gallagher & Co.

Registration Statement on Form S-4 (File No. 333-268400)

Ladies and Gentlemen:

Pursuant to Rules 460 and 461 promulgated under the Securities Act of 1933, as amended, the registrant, Arthur J. Gallagher & Co. (the “Company”), respectfully requests the acceleration of the effectiveness of the above-referenced Registration Statement (the “Registration Statement”), so as to become effective at 4:00 p.m. Eastern time on Monday, November 28, 2022 or as soon as possible thereafter.

Please do not hesitate to contact Andrew L. Fabens of Gibson, Dunn & Crutcher LLP at (212) 351-4034 or Robert D. Giannattasio of Gibson, Dunn & Crutcher LLP at (212) 351-6234, with any questions or comments with respect to this letter.

Very truly yours,
By:	/s/ Seth Diehl
	Seth Diehl
	Assistant Secretary