November 14, 2019

Neal V. Fenwick
Chief Financial Officer
ACCO Brands Corporation
Four Corporate Drive
Lake Zurich, Illinois 60047

       Re: ACCO Brands Corporation
           Form 10-K for the Year Ended December 31, 2018
           Form 10-Q for the Quarter Ended September 30, 2019
           File No. 001-08454

Dear Mr. Fenwick:

       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 December 31, 2018

Selected Financial Data
Supplemental Non-GAAP Financial Measures - Comparable Net Sales
Adjusted Operating Income and Adjusted Earnings per Share, page 24

1.    We note your presentation of Reported GAAP financial measures to Adjusted
Non-GAAP
      financial measures in the table on page 24. Please revise your
presentation to include
      individual reconciliations for each adjusted non-GAAP measure in the
table as we do not
      consider the current income statement reconciliation style to comply with
the
      requirements of Item 10(e) of Regulation S-K. Additionally, for each
non-GAAP financial
      measure presented, please provide disclosures required by Item
10(e)(1)(i)(c-d) of
      Regulation S-K. The disclosures provided by management should be specific
to each
      measure and management should avoid using generic boilerplate language
when
      describing its usefulness to investors.
 Neal V. Fenwick
ACCO Brands Corporation
November 14, 2019
Page 2
Form 10-Q for the Quarter Ended September 30, 2019

Financial Statements
Notes to Condensed Consolidated Financial Statements (Unaudited)
11. Income Taxes
Immaterial Out-of-Period Adjustment, page 23

2.       We note that in the first quarter of 2019, you recorded a $5.6 million
tax expense that
         related to the fourth quarter of 2018. We further note that you
believe this correction was
         not material. Given that the adjustment recognized during 2019 of $5.6
million
         represented 16% of your fourth quarter 2018 net income as well as
resulted in a net loss in
         your first quarter 2019, please tell us how you considered materiality
in the context
         of SAB Topic 1M and provide us with your detailed analysis in
determining the out-of-
         period adjustment was not material to your results of operations for
the quarters ended
         December 31, 2018 and March 31, 2019.
       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 Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
with any
questions.



FirstName LastNameNeal V. Fenwick                             Sincerely,
Comapany NameACCO Brands Corporation
                                                              Division of
Corporation Finance
November 14, 2019 Page 2                                      Office of
Manufacturing
FirstName LastName