SecProbe.io

May 11, 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
Form 10-Q for Fiscal Quarter Ended February 28, 2011 Filed April 1, 2011
  Commission File No.:  1-14920

Dear Mr. Kelly:
We have reviewed your response letter dated April 20, 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 one you indicate that significant effort  and cost would be
required to accumulate the information necessa ry to provide disclosure of the revenue
attributable to specialty foods.  Please describe  for us this effort and cost and explain to
us how you determined it was significant.  In addition, clarify for us whether the
significant effort and cost would be incurre d one time as a start- up cost, or annually.
 2. We have considered your response to prior comment three and the accompanying
materials.  Please explain to us how you have considered:

Kenneth A. Kelly, Jr.
McCormick & Company, Incorporated May 11, 2011 Page 2

• Whether each of the ten components identi fied in your “blue sheets” (e.g., EMEA
Consumer, Canada Consumer, etc.) repr esent distinct operating segments, under
ASC 280-10-50-1.  In this re gard, it appears that your  CODM regularly reviews
discrete financial information for th ese components, and your planning and
budgeting process appears to provide di saggregated information for each
component to your CODM for resource allocation purposes.

• ASC 280-10-50-8 and the fact that ther e are segment managers for the ten
individual components and no one is held responsible for total consumer and total
industrial.

Please provide any additional analysis nece ssary to support your determination of
operating segments.  If you ultimately determ ine that the ten indi vidual components are
operating segments, provide us a comprehens ive analysis of your determination of
reportable segments under ASC 280-10- 50-10 through 50-19, including supporting
calculations for any compound annual growth ra te amounts utilized as part of ASC 280-
10-50-11.  If necessary, please reevaluate your determination of reporting units under
ASC 350-20-35-23 through 35-46.

You may contact Michael Fay at (202) 551-3812 or Mark Shannon at (202) 551-3299 if
you have questions regarding the comments and rela ted matters.  Please contact me with any
other questions at 202-551-3489.

 Sincerely,
         / s /  B r a d  S k i n n e r
 Brad Skinner
        Senior Assistant Chief Accountant