February 13, 2020

Karen J. Holcom
Chief Financial Officer
ACUITY BRANDS INC
1170 Peachtree Street, N.E.,
Suite 2300
Atlanta, GA 30309

       Re: ACUITY BRANDS INC
           Form 10-K for the Fiscal Year Ended August 31, 2019
           Filed October 29, 2019
           File No. 001-16583

Dear Ms. Holcom:

       We have reviewed your filing and have the following comments. 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 August 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 23

1.    We note that on page 24 and in your earnings releases you present certain
non-GAAP
      measures, such as Adjusted SD&A expenses and Adjusted operating profit,
as a
      percentage of net sales without also presenting the most directly
comparable GAAP
      measures. In addition, you discuss Adjusted operating profit margin in
your earnings
      releases without providing a discussion of GAAP operating profit margin.
When
      presenting or discussing non-GAAP measures in your future filings, please
present and
      discuss the most directly comparable GAAP measures with equal or greater
prominence.
      Refer to Item 10(e)(i)(A) of Regulation S-K and Question 102.10 of the
updated
      Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
 Karen J. Holcom
FirstNameBRANDS INC J. Holcom
ACUITY LastNameKaren
Comapany NameACUITY BRANDS INC
February 13, 2020
February 13, 2020 Page 2
Page 2
FirstName LastName
Notes to Consolidated Financial Statements
Note 11 - Commitments and Contingencies, page 70

2.       Tell us how your use of the terms "reserve", "reserves" and "reserved"
when referring to
         your accruals for loss contingencies is consistent with the guidance
in ASC 450-20-50-1,
         or revise your disclosures in future filings to comply with the
guidance.
        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.

      You may contact SiSi Cheng at 202-551-5004 or Martin James, Senior
Advisor, at 202-
551-3671 with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing