Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas
New York, New York 10019-6064
August 17, 2016
Via EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Ply Gem Holdings, Inc.
Registration Statement on Form S-3
Ladies and Gentlemen:
On behalf of our client, Ply Gem Holdings, Inc. (the “Company”), we are transmitting for filing with the Securities and Exchange Commission in electronic form a Registration Statement on Form S-3 (the “Registration Statement”).
The filing fee in respect of the Registration Statement has been paid.
Should you have any questions regarding the Registration Statement, please feel free to contact Jennifer Wang at (212) 373-3947 or the undersigned at (212) 373-3025.
Very truly yours,
/s/ John C. Kennedy
John C. Kennedy
tim.johnson@plygem.com
Ply Gem Holdings, Inc.