[Calfee, Halter & Griswold LLP Letterhead]
November 14, 2017
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Mr. Terence O’Brien | |||
| Accounting Branch Chief | ||||
| Office of Manufacturing and Construction | ||||
| Re: | RPM International Inc. | |||
| Form 10-K for the Year Ended May 31, 2017 | ||||
| Filed July 24, 2017 | ||||
| Response Letter dated October 16, 2017 | ||||
| File No. 1-14187 | ||||
Dear Mr. O’Brien:
On behalf of RPM International Inc. (the “Company”), this letter confirms the receipt by the Company of the comment provided by the staff of the Securities and Exchange Commission, Division of Corporation Finance (the “Commission”), dated November 6, 2017 (the “Comment Letter”). The Company is hereby formalizing its prior verbal request for additional time to respond to the Comment Letter due to constraints on the availability of Company personnel. Absent your response denying this request, the Company anticipates it will file its response to the Comment Letter on or before Tuesday, December 5, 2017.
Please do not hesitate to contact me at (216) 622-8253 if you have any questions or would like to discuss this request in more detail.
| Very truly yours, |
| /s/ Gregory S. Harvey |
| Gregory S. Harvey |
| cc: | Russell L. Gordon |
| Edward W. Moore |
| John J. Jenkins |
