SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

January 30, 2008

Via U.S. mail and facsimile

Ms. Elizabeth A. Nickels
Chief Financial Officer
Herman Miller, Inc.
855 East Main Avenue
Zeeland, Michigan 49464

 RE: Form 10-K for the fiscal year ended June 2, 2007
  Form 10-Q for the period  ended December 1, 2007
Form 8-K filed on November 27, 2007
   File No. 1-15141

Dear Ms. Nickels:

  We have reviewed your filing and have the following comments.  We have
limited our review of your filing to those issues  we have addressed in our comments.  If
you disagree with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
or may not raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED JUNE 2, 2007

General

1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.  These revisions should be included in your future filings.

Ms. Elizabeth A. Nickels
January 30, 2008
Page 2 of 4
Management’s Discussion and Analysis

Discussion of Business Segments, page 21

2. Please expand your discussion about segment results to discuss the business reasons
for changes in your operating earnings betw een periods.  For example, you state that
operating earnings in fiscal 2007 were $161.7 million, or 10.3 percent of net sales for the North American Furniture Solutions segment.  This compares to $139.9 million or 9.7 percent in the prior year.  You should clearly explain th e factors that led to the
increase in operating earnings from $139.9 million to $161.7 million as well as the
increase of operating earnings as a percentage of revenue from 9.7 percent to 10.3 percent.  In addition, when there is more  than one factor for a change between
periods, please quantify the extent to whic h each factor contributed to the overall
change in net sales and operating earnings .  Please also consid er adding a discussion
regarding changes in each segment’s gross margin between periods.

Financial Statements

Notes to the Financial Statements

Note 1.  Significant Accounting and Reporting Policies

Accounts Receivable Allowances, page 47

3. Please expand your discussion to address whic h statement of operations line items are
used to record accounts r eceivable allowances as we ll as how you determine which
line item to use to record these allowances .  Specifically, please disclose in which
circumstances you record accounts receivable allowances as a reduction to net sales
and in which circumstances you record accounts  receivable allowances as an increase
to selling, general and administrative expense or other expense line items.  Please also
address the following:
• Please help us understand how you determined it was appropriate to record the reduction to your balance sheet reserves of $13.0 million in the fourth quarter of
2005 related to General Services Admini stration contracts as a reduction to
selling, general and administrative expenses in stead of as an increase to net sales.
Please tell us which statement of operat ions line item was used to record the
original reserves;
• For each of the last three fiscal years as  well as the current interim period, please
tell us the amount recorded to each stat ement of operations line item used to
increase accounts receivable allowances during the period.  For example, please
tell us the amount recorded as a reduction to net sales separately from the amount recorded to selling, general, and admini strative expenses or other expense line
items.  Please clarify if any of the allo wances recorded as selling, general and
administrative expenses or in any other expense line item were for reasons other

Ms. Elizabeth A. Nickels
January 30, 2008
Page 3 of 4
than those associated with  creditworthiness.  If s o, tell us the corresponding
amounts recorded during each period;
• For each of the last three fiscal years as  well as current interim period, please tell
us the amount recorded to each statement of  operations line item used to decrease
accounts receivable allowances during the pe riod.  For example, please tell us the
amount recorded as an increase to net sa les separately from the amount recorded
to selling, general, and administrative e xpenses or other e xpense line items.
Please clarify if any of the reductions to  the allowance thro ugh selling, general
and administrative expenses or in any ot her expense line item were for reasons
other than those associated with creditworthiness.  If so, tell us the corresponding
amounts recorded during each period; and
• In Schedule II (Valuation and Qualifying Accounts), please pres ent changes to the
allowance for possible losses on accounts receivable separately for each statement of operations line item used to record these changes.

FORM 10-Q FOR THE PERI OD ENDED DECEMBER 1, 2007

General

4. Please address the above comments in your interim filings as well.

FORM 8-K FILED ON NOVEMBER 27, 2007

5. You disclosed earnings per share guidance after excluding a one-t ime charge.  This
amount constitutes a non-GAAP financial measure.  We remind you that Item
100(a)(1) of Regulation G requires you to  accompany non-GAAP financial measures
with a presentation of the most directly co mparable financial measure calculated and
presented in accordance with GAAP.  In future  filings, please ensure that you comply
with the disclosure requirements of  Regulation G when presenting non-GAAP
financial measures, which include presen ting the most directly comparable GAAP
amount.

*    *    *    *

  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
information.  Detailed letters greatly facilitate our review.  Please file your supplemental
response on EDGAR as a correspondence file .  Please understand that we may have
additional comments after reviewin g your responses to our comments.

Ms. Elizabeth A. Nickels
January 30, 2008
Page 4 of 4
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in their
filings;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to 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.

  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

If you have any questions regarding these comments, please direct them to Nudrat
Salik, Staff Accountant, at ( 202) 551-3692 or, in her absence,  to the undersigned at (202)
551-3769.

       S i n c e r e l y ,

       R u f u s  D e c k e r
       Accounting Branch Chief