SecProbe.io

April 4, 2011
 Via E-mail

Kenneth A. Kelly, Jr. Senior Vice President & Controller McCormick & Company, Incorporated 18 Loveton Circle Sparks, Maryland  21152

Re: McCormick & Company, Incorporated
  Form 10-K for Fiscal Year Ended November 30, 2010   Filed January 27, 2011   File No. 1-14920

Dear Mr. Kelly:
We have reviewed your response letter dated March 18, 2011 and have the following
comments.
 Please respond to this letter within te n business days by amending your filings, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your f ilings and the information you provide in
response to these comments, we may have additional comments.

Form 10-K for Fiscal Year Ended November 30, 2010

 Exhibit 13

 Note 16:  Business Segments, page 55

1. In response to prior comment five, you stat e that revenue disclosure under ASC 280-10-
50-40 is not required since the products with in each of your segments are fairly
homogenous and that you do not sell disparate product lines.  You also indicate that you
do not currently accumulate the necessary info rmation and that it would be impracticable
to do so.  Your response does not appear to fully address that you sell specialty foods, as
disclosed in your MD&A on page 17 of your 2010 Annual Report (executive summary
section).  Specialty foods appears dissimila r to your flavor products, based upon the
information provided on your website.  While  we understand your belief that it is
impracticable to provide revenue disclosu re related to your ma ny different flavor

Kenneth A. Kelly, Jr.
McCormick & Company, Incorporated April 4, 2011 Page 2

 products, please explain to us how you have co nsidered, or why it is impracticable, to
disclose revenue attributable to (i) fl avor products and (ii) specialty foods.
 2. In response to prior comment six, you indicate  that the CODM does not regularly review
operating results in a manner for which the respon sibilities of the three presidents fall.
Please clarify for us whether these operating results are actually prepared, the frequency
they are reviewed by the CODM, if applicable , and the reason they are presented to, and
reviewed by, the CODM, if applicable.
 3. In addition, we note that your form of or ganization results in  certain overlapping
responsibilities, similar to a matrix form of organization.  To help us better understand
the basis for your segment presentation, please:
• Provide us the 2010 operating results pack age regularly reviewed by the CODM,
and any additional operating re sults package that may be reviewed by the CODM;
• Describe for us the significant resources  allocation decisions made by the CODM;
• Provide us the operating results package provided to your Board of Directors;
• Describe for us the any annual opera ting and capital expenditure budgeting
processes undertaken by your company, in cluding the prepar ation and approval
steps, and any participation by your  presidents and the CODM; and
• Identify for us the financial information utilized by your CODM to prepare for the
quarterly earnings conference calls and tell us how you have considered this
information in your determination of operati ng segments, particularly as it relates
to the characteristic of assessing performance under ASC 280-10-50-1(b).
 Closing Comments

You may contact Michael Fay at (202) 551-3812 or me at  (202) 551-3299 if you have
questions regarding the comments.

 Sincerely,
  /s/ Mark C. Shannon   Mark C. Shannon         B r a n c h  C h i e f