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