SecProbe.io

January 24, 2014

Via E -mail
Mr. Gregory J. Bylsma
Chief Financial Officer
Herman Miller , Inc.
855 East Main Avenue
Zeeland, MI 49464 -0302

Re: Herman Miller , Inc.
  Form 10 -K for the year ended June 1, 2013
Filed July 30 , 2013
File No. 1-1514 1

Dear Mr. Bylsma :

We have reviewed your filing  and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for the year ended June 1, 2013

Management’s Discussion and Analysis, page 15

Executive Overview, page 15

1. You dis close that the North American reportable segment is the aggregation of two
operating segments. Please identify these two operating segments and tell us how you
considered ASC 280 -10-50 in identifying your operating segments and how your
reporting segments  meet the aggregation criteria set forth in ASC 280 -10-50-11. You
may wish to provide us supplementally with an analysis that includes historical revenues,
gross profits, gross profit margins, operating profits, and operating profit margins, along
with any other information you believe would be useful for each of your operating
segments to help us understand how these operations are economically similar and
aggregation is appropriate.

Mr. Gregory J. Bylsma
Herman Miller , Inc.
January 24, 2014
Page 2

 Financial Results, page 20

2. We note from the tables on pages 21 -22 the significant impact that “Change in other
volumes” has on your net sales. Please provide draft disclosure , to be included in future
filings that  discusses the material components of this line item and the reasons for the
significant increase during fiscal  2013.  Ensure that your disclosure discusses not only
volume changes of existing products but the impact of any product introductions.  In this
regard, we note from your Q2 2014 earnings call transcript you anticipate Living Office
systems to begin standa rd order entry in the first half of 2014 and have begun recognizing
revenue on the first shipments related to the large energy project.

2. Acquisitions and Divestitures, page 50

3. Please provide to us your significance calculations for the Maharam  acquisition under the
asset, investment and income tests as prescribed by Rule 3 -05 of Regulation S -X and tell
us your basis for not providing financial statements under Rule 3 -05 for this acquisition.

We urge all persons who are responsible for the acc uracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all fact s relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsib le for the adequacy and accuracy of the disclosure in the filing;
 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.

You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3854 if you have
questions regarding comments on the f inancial statements and related matters.

Sincerely,

 /s/ Melissa N. Rocha

Melissa N. Rocha
Senior Assistant  Chief  Accountant