March 18, 2019 Andrew B. Nace Executive Vice President, General Counsel, and Secretary Valhi, Inc. 3 Lincoln Center 5430 LBJ Freeway, Suite 1700 Dallas, TX 75240-2697 Re: Valhi, Inc. Registration Statement on Form S-3 Filed March 11, 2019 File No. 333-230189 Dear Mr. Nace: 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