One Liberty Plaza, 7th Floor New York, N.Y. 10006 Office: (212) 297-0200 Fax: (212) 297-0375

May 1, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attention: Ta Tanisha Meadows and Joel Parker

Re: ABM Industries Incorporated

Form 10-K for Fiscal Year Ended October 31, 2024

Form 8-K Filed December 18, 2024

File No. 1-08929

Ladies and Gentlemen:

On behalf of ABM Industries Incorporated (referred to as “ABM,” “we,” “our,” or the “Company”), we acknowledge receipt of the Staff’s response dated April 25, 2025, regarding our non-GAAP reconciliation presented in the Form 8-K filed on December 18, 2024, specifically related to the adjustment for “Prior year self-insurance adjustment.”

We respectfully confirm that we will revise our presentation in future filings and earnings materials to exclude the Prior year self-insurance adjustment from our calculation of non-GAAP financial measures, consistent with the Staff’s guidance and in accordance with Item 10(e) of Regulation S-K or Regulation G.

If you have any questions or need further information, please email me at earl.ellis@abm.com.

Very truly yours,

/s/ Earl R. Ellis

Executive Vice President and

Chief Financial Officer