SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561
May 29, 2009
Via U.S. Mail
Michael T. Dan
Chairman and Chief Executive Officer
The Brink’s Company
P.O. Box 18100
1801 Bayberry Court
Richmond, Virginia 23226
Re: The Brink’s Company
Form 10 -K
Filed: March 2, 2009
File No.001-09148
Dear Mr.Dan:
We have reviewed your filing and have the following comments. Where
indicated, we think you should implement these comment sin future filings. If you
disagree, we will consider your explanation as to why ou r comments are inapplicable or
implementation 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 in formation, we may raise
additional comments.
Please understand that the purpose of our review 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 t o working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Management’s Report on Internal Control ov er Financial Reporting, page 58
1.We note your use of the pronoun “we” in this section. In future filings, please
revise your disclosure to clarify that the representations required by Item 308(a)
of Regulation S -K are made by your “management.” Refer to It em 308(a)(1) -(3)
of Regulation S -K.

Michael T. Dan
The Brink’s Company
May 29 , 2009
Page 2
Exhibit 10(aa)(i)
2.We note you have incorporated by reference Exhibit 10(aa)(i). This filing does
not include the exhibits referenced in the agreement. All exhibits must be filed in
full and include all attachments, schedules and exhibits. Please refile this exhibit
with all attachments, schedules andexhibits in your ne xtExchange Act filing .
Exhibit 10(aa)(iii)
3.We note you have incorporated by reference Exhibit 10(aa)(iii). This filing does
not include Exhibit A referenced in the agreement. All exhibits must be filed in
full and include all attachments, schedules and exhibits. Please refile this exhibit
with all attachments, schedules and exhibits in your ne xtExchange Act filing .
Exhibit 10(bb)
4.We note you h ave incorporated by reference Exhibit 10(bb).This filing does not
include the schedules listed in the table of contents of the agreement. All exhibits
must be filed in full and include all attachments, schedules and exhibits. Please
refile this exhibit with all attachments, schedules and exhibits in your ne xt
Exchange Act filing .
Exhibit 10 (cc)(i)
5.We note you have incorporated by reference Exhibit 10(cc)(i). This filing does
not include the schedules listed in the table of contents of the agreement. All
exhibits must be filed in full and include all attachments, schedules and exhibits.
Please refile this exhibit with all attachments, schedules and exhibits in your ne xt
Exchange Act filing .
Exhibit 10 (dd)
6.We note you have incorporated by reference Exhibit 10(dd). This filing does not
include the schedules and exhibits listed in the table of contents of the agreement.
All exhibits must be filed in full and include all attachments, schedules and
exhibits. Please refile this exhibit with all attach ments, schedules and exhibits in
your ne xtExchange Act filing .
Other
7.Further, please confirm that you will file all e xhibits in full and include all
attachments, schedules and exhibits in future filings.

Michael T. Dan
The Brink’s Company
May 29 ,2009
Page 3
* * * * *
As appropriate, please respond to t hese comments within 10 business days or tell
us when you will provide us with a response.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all information requi red under
the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the company and its
management are in possession of all facts relating to a company’s disclosure, they a re
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 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.
In addition, please be advised that the Division o f Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in our review
of your filing or in response to our comments on your filing.
Please contact Matthew Spitzer at (202) 551 -3227 or me at (202) 551 -3314with
any other questions.
Sincerely,
Daniel Morris
Attorney -Advisor