November 9, 2018 Michael J. Foster, Esq. Senior Vice President and General Counsel LSB Industries, Inc. 3503 NW 63rd Street, Suite 500 Oklahoma City, OK 73116 Re: LSB Industries, Inc. Registration Statement on Form S-3 Filed November 2, 2018 File No. 333-228139 Dear Michael J. Foster: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction