SEC Comment Letter for ECOLAB INC. (ECL) (CIK 0000031462) (ECL) — Jun 20, 2016
ECOLAB INC. (ECL) (CIK 0000031462)
Date: June 20, 2016 · CIK: 0000031462 · Accession: 0000000000-16-081122
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June 16 , 2016 Mail Stop 4631 Via Email Mr. Daniel J. Schmechel Chief Financial Officer Ecolab , Inc. 370 Wabasha Street North St, Paul, Minnesota 55102 Re: Ecolab , Inc. Form 10 -K for F iscal Year Ended December 31, 2015 Filed February 29, 2016 File No. 1-9328 Dear Mr. Schmechel : We have completed our review of your filing s. 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 s 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 s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Terence O ’Brien Terence O’Brien Accounting Branch Chief Office of Manufacturing and Construction