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                              June 10, 2024

       Timothy F. Murphy
       Senior Vice President and Chief Financial Officer
       Gibraltar Industries, Inc.
       3556 Lake Shore Road
       Buffalo, New York 14219

                                                        Re: Gibraltar
Industries, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2023
                                                            Form 8-K filed
February 21, 2024
                                                            File No. 000-22462

       Dear Timothy F. Murphy:

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

              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.

       Form 10-K for Fiscal Year Ended December 31, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Critical Accounting Estimates
       Revenue Recognition on Contracts with Customers, page 29

   1.                                                   We note for certain
contracts you recognize revenue over time under the cost-to-cost
                                                        method which requires
subjective judgment and estimation to determine total costs
                                                        expected to be incurred
at contract completion. You indicate such estimates are updated
                                                        and any changes in
estimates are recognized in the period the change becomes known.
                                                        You also indicate
provisions for estimated losses on uncompleted contracts are made in
                                                        the period such losses
are determined. Please tell us whether you have recognized
                                                        material favorable or
unfavorable changes in estimates with respect to these contracts and
                                                        provide us the gross
amounts of favorable and unfavorable changes recognized during
                                                        each period presented
as part of your response. Please also tell us the amount of contract
                                                        losses recognized
during each period presented and the status of material loss contracts.
                                                        Please revise your
disclosures in future filings to quantify and discuss the gross impacts of
 Timothy F. Murphy
FirstName   LastNameTimothy  F. Murphy
Gibraltar Industries, Inc.
Comapany
June        NameGibraltar Industries, Inc.
     10, 2024
June 10,
Page 2 2024 Page 2
FirstName LastName
         changes in contract estimates, including contract losses, during each
period presented
         pursuant to Item 303(b)(3) of Regulation S-K.
Financial Statements
Notes to Consolidated Financial Statements
(3) Revenue, page 46

2.       We note you disclose contract assets consist of costs in excess of
billings and are
         presented in accounts receivable. Please clarify the nature of the
performance obligations
         that costs in excess of billings relate to and explain if and how you
determined your right
         to this consideration is unconditional. If your right to this
consideration is conditioned on
         something other than the passage of time, please revise your balance
sheet presentation of
         these amounts in future filings or explain how you determined your
current presentation
         complies with ASC 606-10-45-1 and 45-4.
3.       We note you disclose the amounts of revenue recognized during each
year presented that
         were in contract liabilities at the beginning of the respective
periods. Please revise or
         clarify your disclosures in future filings to explain why, in the two
preceding years, the
         amount of revenue recognized exceeded the contract liability balance
at the beginning of
         each respective period.
(13) Fair Value Measurements, page 58

4.       In regard to non-recurring fair value measurements, please revise
future filings to quantify
         and disclose the estimated fair values/carrying values of the impaired
assets.
(20) Segment Information, page 63

5.       Please revise future filings to fully comply with the disclosures
required by ASC 280-10-
         50-41. In this regard, we note you disclose net sales and long-lived
assets by geographic
         region but do not separately disclose net sales and long-lived assets
for the US and any
         other individual foreign country in North America, to the extent
material.
Form 8-K filed February 21, 2024

Exhibit 99.1, page 1

6.       Please revise future filings to address the following labeling/titling
and prominence issues
         related to the non-GAAP financial measures you present:
             We note you label certain GAAP and non-GAAP financial measures
using the same
              titles with centered headings to distinguish GAAP and non-GAAP
amounts. We also
              note certain instances in which you disclose a change in an
amount using a GAAP
              title, but the disclosed change relates to a non-GAAP financial
measure. For example,
              you disclose "net sales increased 5.1%"; however, it appears
adjusted net sales
              increased 5.1%. For each non-GAAP financial measure you present,
properly label
              and title it as required by Question 100.5 of the Division of
Corporation Finance   s
 Timothy F. Murphy
Gibraltar Industries, Inc.
June 10, 2024
Page 3
              Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
                We note you discuss certain non-GAAP financial measures but do
not discuss the
              most directly comparable GAAP measure with equal or greater
prominence. For
              example, you discuss adjusted operating margin by segments but do
not discuss
              GAAP operating margin by segment. For each non-GAAP financial
measure you
              discuss, discuss the most directly comparable GAAP measure with
equal or greater
              prominence as required by Question 102.10 of the Division of
Corporation Finance   s
              Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
7.       We note your reconciliations of GAAP Measures to Non-GAAP Financial
Measures
         appear to essentially represent non-GAAP income statements. Please
explain to us how
         you determined your reconciliations are appropriate based on the
guidance in Question
         102.10 of the Division of Corporation Finance   s Compliance &
Disclosure Interpretations
         on Non-GAAP Financial Measures or tell us how you plan to revise them
in future filings.
8.       Please tell us and revise future filings to address the following
related to the non-GAAP
         adjustments you present:
             Fully explain each non-GAAP adjustment.
             Explain and reconcile how the non-GAAP adjustments under the
restructuring
             columns relate to the restructuring expenses disclosed in your
financial statements.
             Fully explain what the non-GAAP adjustments under the portfolio
management
             column represent and how they were determined.

       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 Andi Carpenter at 202-551-3645
or Anne
McConnell at 202-551-3709 with any questions.



FirstName LastNameTimothy F. Murphy                           Sincerely,
Comapany NameGibraltar Industries, Inc.
                                                              Division of
Corporation Finance
June 10, 2024 Page 3                                          Office of
Manufacturing
FirstName LastName