October 28, 2019 Carlos Macau, Jr. Chief Financial Officer HEICO CORP 3000 Taft Street Hollywood, FL 33021 Re: HEICO CORP Form 10-K for the period ended October 31, 2018 Filed December 20, 2018 File No. 001-04604 Dear Mr. Macau: We have completed our review of your filing. 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 Manufacturing