April 17, 2019

Ana Menendez
Chief Financial Officer
WATSCO INC
2665 South Bayshore Drive
Suite 901
Miami, FL 33133

       Re: WATSCO INC
           Form 8-K filed on February 14, 2019
           Form 10-K for the fiscal year ended December 31, 2018
           Filed on February 28, 2019
           File No. 1-05581

Dear Ms. Menendez:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 8-K filed on February 14, 2019

Exhibit 99.1, page 2

1.    We note you present bullets related to the growth of "EPS" and "net
income" under full
      year 2018 results and fourth quarter results that quantify changes
relative to the
      comparative periods; however, it appears to us these quantified changes
actually relate to
      comparisons of GAAP measures in the current periods and non-GAAP measures
in the
      comparative periods, as indicated in the related footnotes. It appears to
us these bullets
      are not accurate and do not appear to comply with our response to
Question 102.10 of the
      C&DIs related to Non-GAAP Financial Measures. To the extent applicable,
please revise
      future filings to ensure your disclosures are accurate and comply with
our response to
      Question 102.10 or explain why you believe the current presentation is
appropriate.
 Ana Menendez
FirstName LastNameAna Menendez
WATSCO INC
Comapany NameWATSCO INC
April 17, 2019
Page 17,
April 2 2019 Page 2
FirstName LastName
Form 10-K for the fiscal year ended December 31, 2018

Exhibit 13 - Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Results of Operations, page 5

2.       We note you disclosed that the increase in same-store revenues from
2017 to 2018 was
         "primarily due to realization of price increases, demand for the
replacement of residential
         and commercial HVAC equipment and a higher mix of high-efficiency air
conditioning
         and heating systems, which sell at higher unit prices". We also note
you disclosed in your
         2018 annual earnings release that sales growth in 2018 reflects HVAC
equipment unit
         growth, price increases and a richer mix of high-efficiency systems as
well as margin
         expansion in several markets offset by a profit decline in
Florida-based locations on
         slower sales growth and a profit decline in Latin America on lower
sales. To the extent
         applicable, please revise future filings to:
           Quantify the impacts of changes in price, changes in volume, and
changes in sales mix
             on revenues during each period presented; and
           Quantify and discuss the reasons for differences in changes in
regional sales within the
             United States, to the extent material and necessary to fully
understand changes in
             revenues during each period presented.


       In closing, 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 Mindy Hooker, Accountant, at (202) 551-3732 or Anne
McConnell,
Accountant, at (202) 551-3709 with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Manufacturing and
                                                              Construction