January 15, 2016
By EDGAR
Jay Ingram
Legal Branch Chief
Office of Manufacturing and Construction
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4561
| Re: | Synalloy Corporation |
| Amendment No. 1 to Registration Statement on Form S-3 |
| Filed August 19, 2015 |
| File No. 333-204850 |
| Form 10-K for Fiscal Year Ended January 3, 2015 |
| Filed March 17, 2015 |
| File No. 000-19687 |
| Form 10-Q for Fiscal Quarter Ended July 4, 2015 |
| Filed August 11, 2015 |
| File No. 000-19687 |
| Form 10-Q for Fiscal Quarter Ended October 3, 2015 |
| Filed November 12, 2015 |
| File No. 000-19687 |
Dear Mr. Ingram:
In response to the comment of the staff (the “Staff”) of the Securities and Exchange Commission set forth in your letter dated December 17, 2015 with regard to the above-referenced filings and letter of correspondence dated December 10, 2015, we submit on behalf of Synalloy Corporation (the “Company”) the following supplemental response.
In addition, please be advised that today the Company has filed Amendment No. 2 to Registration Statement on Form S-3 primarily to update the financial information contained therein to reflect financial information relating to the Company’s third quarter of 2015.
| E-mail: scott.richter@leclairryan.com Direct Phone: 804.343.4079 Direct Fax: 804.783.7621 |
919 East Main Street, 24th Floor Richmond, Virginia 23219 Phone: 804.783.2003 \ Fax: 804.783.2294 |
Mr. Jay Ingram
U.S. Securities and Exchange Commission
January 15, 2016
Page 2
Synalloy Corporation Form 10-K for Fiscal Year Ended January 3, 2015
Note 13: Industry Segments, page 46
| 1. | Based on your response to comment 2 in our letter dated October 8, 2015, as well as the information you provided in our telephone conversation on November 6, 2015, it does not appear that the products offered by Palmer are similar to the products offered by BRISMET and Specialty. As such, please expand your disclosures to provide the required disclosures under ASC 280-10-50-40. |
| Response: The Staff’s comment is noted. The Company will revise and expand the noted disclosure in its future filings to ensure the disclosures required under ASC 280-10-50-40 relating to the products offered by Palmer of Texas Tanks, Inc., Bristol Metals, LLC and Specialty Pipe and Tube, Inc. are provided by the Company. |
* * *
Please contact me at (804) 343-4079 or Benjamin A. McCall at (804) 916-7182 should you require further information or if you have any questions.
Very truly yours,
/s/ Scott H. Richter
Scott H. Richter
| cc: | Mr. Frank Pigott |
| Mr. Ameen Hamady |
| Mr. Craig C. Bram |
| Benjamin A. McCall, Esq. |