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October 17, 2008
VIA EDGAR AND TELECOPIER (202-772-9367) | |
Securities and Exchange Commission | |
100 F. Street, N.E. | |
Washington, DC 20549 | |
Attention: Gabriel Eckstein |
RE: | Graybar Electric Company, Inc. and Voting Trustees | |
under Voting Trust Agreement | ||
Registration Statement on Form S-1 | ||
(Registration No. 333-153266) |
Gentlemen: |
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as | |||
amended, Graybar Electric Company, Inc. and the Voting Trustees under the Voting | |||
Trust Agreement, dated as of March 16, 2007, relating to Common Stock issued by | |||
Graybar Electric Company, Inc. hereby request acceleration of the effective date of the | |||
above-captioned Registration Statement so that it may become effective at 9:00 a.m. on | |||
October 22, 2008, or as soon thereafter as practicable. |
In addition, the Company and the Voting Trustees hereby acknowledge that:
n | should the Commission or the staff, acting pursuant to delegated | |
authority, declare the Registration Statement effective, it does not | ||
foreclose the Commission from taking any action with respect to the | ||
filing, | ||
n | the action of the Commission or the staff, acting pursuant to delegated | |
authority, in declaring the Registration Statement effective, does not | ||
relieve the Company or the Voting Trustees from their full | ||
responsibility for the adequacy and accuracy of the disclosure in the filing, and |
n | the Company and the Voting Trustees may not assert staff comments | |
and the declaration of effectiveness as a defense in any proceeding | ||
initiated by the Commission or any person under the federal securities | ||
laws of the United States. |
Please call James R. Levey at (314) 259-2296, if you have any questions or comments. | |||
Thanks for your continued assistance. |
Sincerely, | |
GRAYBAR ELECTRIC COMPANY, INC. |
By: | /s/M. W. Geekie | |
M. W. Geekie, Senior Vice President, | ||
Secretary and General Counsel |
VOTING TRUSTEES | ||
/s/R. A. Reynolds, Jr. | ||
R. A. Reynolds, Jr. | ||
D. E. DeSousa | ||
/s/L. R. Giglio | ||
L. R. Giglio | ||
T. S. Gurganous | ||
/s/R. D. Offenbacher | ||
R. D. Offenbacher |