United States securities and exchange commission logo October 11, 2022 Avner Applbaum Chief Financial Officer Valmont Industries, Inc. 15000 Valmont Plaza Omaha, Nebraska 68154 Re: Valmont Industries, Inc. Form 10-K for Fiscal Year Ended December 25, 2021 Filed February 23, 2022 File No. 001-31429 Dear Avner Applbaum: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Manufacturing