September 16, 2008
U.S. Securities and Exchange Commission | |
Division of Corporation Finance | |
100 F Street, N.E. | |
Washington, DC 20549 | |
Attention: Angela Crane and Julie Sherman |
Re: | Graybar Electric Company, Inc. | |
Form 10-K for the fiscal year ended December 31, 2007 | ||
File No. 000-00255 |
Ladies and Gentlemen: | |
On behalf of Graybar Electric Company, Inc., I am transmitting with this letter | |
Amendment No. 2 to the above-referenced filing following previous correspondence and | |
telephone conversations between members of the Staff and our outside counsel, James R. | |
Levey of Bryan Cave LLP. | |
We appreciate the Staff’s review. If you require any additional information regarding | |
this matter, or if you require any other information that would facilitate the completion of | |
your review of this filing, please advise Mr. Levey at your earliest convenience. You | |
may reach Mr. Levey at 314-259-2296, or by fax at 314-552-8296. You may also contact | |
me at 314-573-9278, or by fax at 314-573-9445. | |
Very truly yours, |
/s/ MATTHEW W. GEEKIE | |
Matthew W. Geekie | |
MWG/cg | |
Enclosure |
cc: | Mr. D. Beatty D’Alessandro, Senior Vice President and Chief Financial Officer, | |
Graybar Electric Company, Inc. | ||
Mr. Martin J. Beagen, Vice President and Controller, Graybar Electric Company, Inc. | ||
Alice W. Lehnhoff, Esq., Corporate Counsel, Graybar Electric Company, Inc. | ||
James R. Levey, Esq., Partner, Bryan Cave LLP |