May 7, 2025 Earl Ellis Chief Financial Officer ABM Industries Incorporated One Liberty Plaza, 7th Floor New York, NY 10006 Re: ABM Industries Incorporated Form 10-K for Fiscal Year Ended October 31, 2024 File No. 1-08929 Dear Earl Ellis: We have completed our review of your filings. 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 Trade & Services cc: Dean Chin, Chief Accounting Officer