February 22, 2019

Todd R. Moore
Executive Vice President
NCI Building Systems, Inc.
5020 Weston Parkway, Suite 400
Cary, NC 27513

       Re: NCI Building Systems, Inc.
           Registration Statement on Form S-3
           Filed February 20, 2019
           File No. 333-229743

Dear Mr. Moore:

       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 Sherry Haywood, Staff Attorney at (202) 551-3345 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing and
                                                            Construction