SEC Comment Letter for Avery Dennison (AVY) — Oct 24, 2011

Avery Dennison Corp
Date: Oct. 24, 2011 · CIK: 0000008818 · Accession: 0000000000-11-061959

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AI Filing Summary & Sentiment

File numbers found in text: 001-07685

Date

October 24, 2011

Author

/s/ Pamela Howell

Form

UPLOAD

Company

Avery Dennison Corp

Letter

October 24, 2011 Via E-mail Dean A. Scarborough, Chief Executive Officer Avery Dennison Corporation 150 North Orange Grove Boulevard Pasadena, California 91103 RE: Avery Dennison Corporation Form 10-K for Fiscal Year Ended January 1, 2011 Filed February 28, 2011 File No. 001-07685

Dear Mr. Scarborough: We have completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Pamela Howell for John Reynolds Assistant Director

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October 24, 2011
 Via E-mail

Dean A. Scarborough, Chief Executive Officer Avery Dennison Corporation 150 North Orange Grove Boulevard Pasadena, California  91103           RE:  Avery Dennison Corporation
                 Form 10-K for Fiscal Year Ended January 1, 2011
                 Filed February 28, 2011                  File No. 001-07685

Dear Mr. Scarborough:
We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
 Sincerely,
  /s/ Pamela Howell
 for
  John Reynolds
Assistant Director

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