United States securities and exchange commission logo August 25, 2020 K.M. Mazzarella Chief Executive Officer Graybar Electric Company, Inc 34 North Meramec Avenue St. Louis, Missouri 63105 Re: Graybar Electric Company, Inc. Registration Statement on Form S-1 Filed August 20, 2020 File No. 333-248195 Dear Mr. Mazzarella: 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 Jennifer L pez at 202-551-3792 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services