December 10, 2019

Heather Clark or Jean Yu

United States Securities Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

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 Ms. Clark or Ms. Yu,

This letter is in response to your comment letter dated November 14, 2019, addressed to Neal V. Fenwick, Chief Financial Officer of ACCO Brands Corporation.

As discussed with you on November 19, our period to respond was extended to December 10. As agreed with you on December 9, 2019, we hereby request that the Commission extend the time for ACCO Brands Corporation to provide the requested response until December 20, 2019.

Please advise the undersigned as soon as possible if there is any question.

Sincerely,

 /s/ Kathleen D. Hood

Kathleen D. Hood

Senior Vice President,

Chief Accounting Officer