SEC Comment Letter for ECOLAB INC. (ECL) (CIK 0000031462) (ECL) — May 31, 2013
ECOLAB INC. (ECL) (CIK 0000031462)
Date: May 31, 2013 · CIK: 0000031462 · Accession: 0000000000-13-029766
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May 31, 2013 Via E -mail Mr. Daniel J. Schmechel Chief Financial Officer Ecolab Inc. 370 Wabasha Street North St. Paul, MN 55102 Re: Ecolab Inc. Form 10 -K Filed February 26 , 2013 File No. 1 -9328 Dear Mr. Schmechel : We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Terence O ’Brien Terence O’Brien Branch Chief