WEIL, GOTSHAL & MANGES LLP AUSTIN 767 FIFTH AVENUE o NEW YORK, NY 10153-0119 BOSTON (212) 310-8000 BRUSSELS FAX: (212) 310-8007 BUDAPEST DALLAS FRANKFURT HOUSTON LONDON MIAMI MUNICH PARIS PRAGUE SHANGHAI SILICON VALLEY DIRECT LINE October 7, 2004 SINGAPORE 212-310-8566 WARSAW michael.lubowitz@weil.com WASHINGTON, D.C. VIA EDGAR TRANSMISSION Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: REGISTRATION STATEMENT ON FORM S-4 OF BUILDING MATERIALS CORPORATION OF AMERICA Ladies and Gentlemen: On behalf of our client, Building Materials Corporation of America, a Delaware corporation (the "Issuer"), and in connection with the registration under the Securities Act of 1933, as amended, of up to $200,000,000 in aggregate principal amount of the Issuer's 7-3/4% Senior Notes due 2014 issuable in the proposed exchange offer for $200,000,000 in aggregate principal amount of the Issuer's 7-3/4% Senior Notes due 2014, transmitted herewith for filing is the Registration Statement, together with certain exhibits. A filing fee of $25,340.00 was deposited by wire transfer into the Commission's account at Mellon Bank, account number 910-8739, on October 6, 2004. We respectfully request that the staff advise the undersigned at (212) 310-8566 of any comments that the staff may have. Very truly yours, /s/ Michael E. Lubowitz Michael E. Lubowitz