June 13, 2005

Mr. David W. Kay
Chief Financial Officer
Gibraltar Industries, Inc.
3556 Lake Shore Road
P.O. Box 2028
Buffalo, NY  14219

RE:  	Form 8-K Item 4.01 (401k Plan) filed June 10, 2005
	File # 0-22462

Dear Mr. Kay:

We have reviewed your filing and have the following comments.
Where
indicated, we think you should revise your documents in response
to
these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone number
listed
at the end of this letter.

1. You currently disclose that there were no disagreements with
your
former accountants during the fiscal years ended December 31, 2003
and 2002.  Please amend your filing to cover the interim period
from
the date of the last audited financial statements, December 31,
2003,
to June 6, 2005, the date of resignation.  See Item 304(a)(1)(IV)
of
Regulation S-K.

2. You currently disclose that you did not consult with Freed
Maxick
& Battaglis CPA`s, P.C. during the fiscal years ended December 31,
2003 and 2002.  Please amend your filing to cover the interim
period
from the date of the last audited financial statements, December
31,
2003, to June 6, 2005, the date of engagement.  See Item 304(a)(2)
of
Regulation S-K.

3. To the extent that you make changes to the Form 8-K to comply
with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.

*****

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require.  Since
the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please file your response via EDGAR in response to these comments
within 5 business days of the date of this letter.  Please note
that
if you require longer than 5 business days to respond, you should
contact the staff immediately to request additional time.  You may
wish to provide us with marked copies of each amended filing to
expedite our review.  Direct any questions regarding the above to
the
undersigned at (202) 551-3866.

Sincerely,


Jeffrey Gordon
Staff Accountant
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David W. Kay
Chief Financial Officer
June 13, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE