[VULCAN LETTERHEAD]
November 5, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attention: Jonathan Burr
| Re: | Vulcan Materials Company |
Registration Statement onForm S-4 |
Filed October 19, 2018 |
FileNo. 333-227903 |
Dear Mr. Burr:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Vulcan Materials Company hereby respectfully requests that the Securities and Exchange Commission accelerate the effective date of its Registration Statement on FormS-4 (FileNo. 333-227903) (the “Registration Statement”) and declare the Registration Statement effective as of Wednesday, November 7, 2018, at 4:30 p.m., Eastern time, or as soon as practicable thereafter.
Please contact Sudhir N. Shenoy of Womble Bond Dickinson (US) LLP at (704)331-4970 with any questions. Also, please notify Mr. Shenoy when this request for acceleration has been granted.
| Very truly yours, | ||
| VULCAN MATERIALS COMPANY | ||
| By: | /s/ Jerry F. Perkins Jr. | |
| Jerry F. Perkins Jr. | ||
| General Counsel and Secretary | ||
| cc: | Sudhir N. Shenoy |
Womble Bond Dickinson (US) LLP
