August 5, 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
           Response Dated June 24, 2024
           File No. 000-22462
Dear Timothy F. Murphy:

       We have reviewed your June 24, 2024 response to our comment letter 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. Unless we
note otherwise, any references to prior comments are to comments in our June
10, 2024 letter.

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 note your response to prior comment 1; however, we also note Item
303(b)(3) of
       Regulation S-K requires for each critical accounting estimate (CAE) made
in accordance
       with generally accepted accounting principles 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 address the following:
why the CAE is
       subject to uncertainty; how much the CAE or assumption (or both) changed
during the
       relevant periods; and the sensitivity of reported amounts to the
methods, assumptions, and
       estimates underlying the CAE   s calculation. Based on the requirements
and the
       information provided in your response, it appears you should revise
future filings to
       disclose and discuss the impact of favorable and unfavorable changes in
contract
 August 5, 2024
Page 2

       estimates and estimated contract losses during each period presented. If
you believe the
       disclosures are not material, please provide your SAB 99 materiality
analysis of the
       factors you considered in your assessment. Please be advised since these
estimates impact
       Operating Income and Net Income, any materiality assessment you provide
should not be
       limited to the impact on revenue and gross profit. In addition, please
tell us your
       consideration of the disclosure requirements of ASC 250-10-50-4.

Notes to Consolidated Financial Statements
(3) Revenue, page 46

2.     We note your response to prior comment 2 states costs in excess of
billings represent
       contract assets and your right to this consideration is conditioned on
something other than
       the passage of time; however, we also note accounts receivable and costs
in excess of
       billings are presented in the same line item in your consolidated
balance sheets.
       Notwithstanding your disclosures of accounts receivable and costs in
excess of billings in
       the notes to the financial statements, it is not clear how you
determined the current
       presentation in your consolidated balance sheets complies with ASC
606-10-45-1. Please
       advise or revise future filings as appropriate.
Form 8-K filed February 21, 2024
Exhibit 99.1, page 1

3.     We note your responses to prior comments 7 and 8. Please revise future
filings to address
       the following:
           We acknowledge your non-GAAP reconciliations exclude certain line
items included
           in your statements of operations; however, we note your
reconciliations include
           every line item from the subtotal for Income from Operations through
earnings per
           share. We continue to believe your current presentations includes
most of the line
           items and subtotals included in your statements of operations and
should be revised in
           future filings to comply with Question 102.10(c) of the Compliance
and Disclosure
           Interpretations for Non-GAAP Financial Measures.
           We note your non-GAAP reconciliations include a subtotal you
identify as    Segments
           income   . Since the subtotal represents a non-GAAP measure that
does not comply
           with Question 100.01 of the Compliance and Disclosure
Interpretations for Non-
           GAAP Financial Measures, revise your reconciliations in future fling
to delete this
           subtotal.
           Revise your non-GAAP reconciliations in future filing to clearly
explain and describe
           each non-GAAP adjustment as required by Question 100.05 of the
Compliance and
           Disclosure Interpretations for Non-GAAP Financial Measures.
 August 5, 2024
Page 3

       Please contact Andi Carpenter at 202-551-3645 or Anne McConnell at
202-551-3709 if
you have questions regarding comments on the financial statements and related
matters.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Manufacturing