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United States securities and exchange commission logo
March 26, 2021
James E. Perry
Chief Financial Officer
CSW Industrials, Inc.
5420 Lyndon B. Johnson Freeway, Suite 500
Dallas, TX 75240
Re: CSW Industrials,
Inc.
Form 10-K for the
Fiscal Year Ended March 31, 2020
Response dated
March 9, 2021
File No. 001-37454
Dear Mr. Perry:
We have reviewed your March 9, 2021 response to our comment
letter and have the
following comment. In some of our comments, we may ask you to provide us
with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2020
Item 1 - Business
General, page 1
1. We note your response
to our comment that your earnings releases do not contain material
non-public information.
Tell us why your earnings releases routinely and prominently
describe and attribute
changes in revenue as organic for both consolidated and segment
results. Tell us
whether organic revenue changes fluctuate between periods and why the
discussion is not
provided in your periodic reports. Provide us with your analysis that
organic changes in
revenues are not material non-public information.
James E. Perry
FirstName LastNameJames E. Perry
CSW Industrials, Inc.
Comapany
March NameCSW Industrials, Inc.
26, 2021
March2 26, 2021 Page 2
Page
FirstName LastName
You may contact Gary Newberry at (202) 551-3761 or Kevin Kuhar,
Accounting Branch
Chief at (202) 551-3662 if you have questions regarding comments on the
financial statements
and related matters.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences