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SEC Comment Letter for LEGGETT & PLATT INC (LEG) (CIK 0000058492) (LEG) — Apr 13, 2005

LEGGETT & PLATT INC (LEG) (CIK 0000058492)
Date: April 13, 2005 · CIK: 0000058492 · Accession: 0000000000-05-017920

AI Filing Summary & Sentiment

File numbers found in text: 333-123213

Date
April 13, 2005
Author
Jennifer R. Hardy
Form
UPLOAD
Company
LEGGETT & PLATT INC (LEG) (CIK 0000058492)

Letter

April 13, 2005 By facsimile to (314) 259-2020 and U.S. Mail Ernest C. Jett, Esq. Senior Vice President, General Counsel and Secretary Leggett & Platt, Incorporated No. 1 Leggett Road Carthage, MO 64836

RE: Leggett & Platt, Incorporated. Pre-effective Amendment 1 to Registration Statement on Form S-3 Filed April 7, 2005 File No. 333-123213

Dear Mr. Jett:

We reviewed the filing and have the comment below.

1. Refer to prior comment 8. Revise these disclosures that can be read to imply that investors do not have rights under the federal securities laws about the disclosures in the prospectus:

* The third sentence in the second paragraph under "Description of Capital Stock" on page 21.

* The third sentence in the fifth paragraph under "Preferred Share Purchase Rights and Series A Junior Participating Preferred Stock" on page 26.

* The third sentence in the second paragraph under "Certain Charter and Bylaw Provisions" on page 26.

Closing

File an amendment to the S-3 in response to the comment. To expedite our review, you may wish to provide us three marked courtesy copies of the amendment. Include with the filing any supplemental information requested and a cover letter tagged as correspondence that keys the responses to the comment. If you think that compliance with the comment is inappropriate, provide the basis in the letter. We may have additional comments after review of the amendment, the response to the comment, and any supplemental information.

You may direct questions on comments and other disclosure issues to Edward M. Kelly, Senior Counsel, at (202) 942-1978 or me at (202) 942-2864.

Very truly yours,
Jennifer R. Hardy

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

April 13, 2005

By facsimile to (314) 259-2020 and U.S. Mail

Ernest C. Jett, Esq.
Senior Vice President, General Counsel and Secretary
Leggett & Platt, Incorporated
No. 1 Leggett Road
Carthage, MO 64836

RE:	Leggett & Platt, Incorporated.
	Pre-effective Amendment 1 to Registration Statement on Form
S-3
	Filed April 7, 2005
	File No. 333-123213

Dear Mr. Jett:

      We reviewed the filing and have the comment below.

1. Refer to prior comment 8.   Revise these disclosures that can
be
read to imply that investors do not have rights under the federal
securities laws about the disclosures in the prospectus:

* The third sentence in the second paragraph under "Description of
Capital Stock" on page 21.

* The third sentence in the fifth paragraph under "Preferred Share
Purchase Rights and Series A Junior Participating Preferred Stock"
on
page 26.

* The third sentence in the second paragraph under "Certain
Charter
and Bylaw Provisions" on page 26.

Closing

	File an amendment to the S-3 in response to the comment.  To
expedite our review, you may wish to provide us three marked
courtesy
copies of the amendment.  Include with the filing any supplemental
information requested and a cover letter tagged as correspondence
that keys the responses to the comment.  If you think that
compliance
with the comment is inappropriate, provide the basis in the
letter.
We may have additional comments after review of the amendment, the
response to the comment, and any supplemental information.

      You may direct questions on comments and other disclosure
issues to Edward M. Kelly, Senior Counsel, at (202) 942-1978 or me
at
(202) 942-2864.

Very truly yours,

Jennifer R. Hardy

Legal
Branch Chief

cc:	R. Randall Wang, Esq.
      William L. Cole, Esq.
	1 Metropolitan Square, Suite 3600
	St. Louis, MO 63102

	John W. White, Esq.
	Cravath, Swaine & Moore LLP
	Worldwide Plaza
	825 8th Avenue
	New York, NY 10019

Ernest C. Jett, Esq.
April 13, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

</TEXT>
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