September 17, 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 the Fiscal Year Ended December 31, 2023
           Response Dated August 16, 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 comment.

       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 the 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 have reviewed your response to prior comment 1; however, we note you
identified
       Revenue Recognition on Contracts as a Critical Accounting Estimate (CAE)
in MD&A
       and your auditor identified it as a Critical Audit Matter in their audit
report. We also note
       disclosures related to CAEs are meant to supplement, but not duplicate,
descriptions
       of accounting policies provided in the notes to the financial
statements. Rather, Item
       303(b)(3) of Regulation S-K requires that for each critical accounting
estimate that
       involves a significant level of estimation uncertainty and had or is
reasonably likely to
       have a material impact on financial condition or results of operations,
you provide
       qualitative and quantitative information necessary to understand the
estimation
       uncertainty and its impact on the financial statements, including how
much the estimate
       changed during the periods presented. Based on the information provided
in your
 September 17, 2024
Page 2

       response letter and the above requirements, please revise future filings
to disclose and
       discuss the impact of favorable and unfavorable changes in contract
estimates and
       estimated contract losses during each period presented, since it appears
to us they had and
       are reasonably likely to have a material impact on your results of
operations. In addition,
       if accurate and in order to comply with the requirements of ASC
250-10-50-4, please
       revise the notes to your financial statements in future filings to
disclose that there were no
       changes in estimates related to any individual contract that materially
impacted your
       financial statements during the periods presented.
       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.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing