May 14, 2019

G. Michael Callahan, Jr.
Chief Executive Officer
GMS Inc.
100 Crescent Centre Parkway, Suite 800
Tucker, Georgia 30084

       Re: GMS Inc.
           Registration Statement on Form S-3
           Filed May 7, 2019
           File No. 333-231268

Dear Mr. Callahan:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Sergio Chinos, Staff Attorney, at (202) 551-7844 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing and
                                                            Construction
cc:    Kyle G. Healy