November 22, 2016
VIA EDGAR AND ELECTRONIC MAIL
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Suzanne Hayes
| Re: | Arthur J. Gallagher & Co. |
| Registration Statement on Form S-4 (File No. 333-214617) |
Ladies and Gentlemen:
Pursuant to Rules 460 and 461 promulgated under the Securities Act of 1933, as amended, the registrant, Arthur J. Gallagher & Co. (the “Company”), respectfully requests the acceleration of the effectiveness of the above-referenced Registration Statement (the “Registration Statement”), so as to become effective at 4:00 p.m. Eastern time on Monday, November 28, 2016 or as soon as possible thereafter.
Please do not hesitate to contact Andrew L. Fabens of Gibson, Dunn & Crutcher LLP at (212) 351-4034 or Eric M. Scarazzo of Gibson, Dunn & Crutcher LLP at (212) 351-2389, with any questions or comments with respect to this letter.
| Very truly yours, | ||
| By: | /s/ Seth Diehl | |
| Seth Diehl | ||
| Assistant Secretary | ||