SEC Comment Letter for SHERWIN WILLIAMS CO (SHW) (CIK 0000089800) (SHW) — Dec 1, 2006

SHERWIN WILLIAMS CO (SHW) (CIK 0000089800)
Date: Dec. 1, 2006 · CIK: 0000089800 · Accession: 0000000000-06-059013

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Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

December 1, 2006

Author

B r a n c h C h i e f

Form

UPLOAD

Company

SHERWIN WILLIAMS CO (SHW) (CIK 0000089800)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 7010 December 1, 2006 Mr. Sean P. Hennessy Senior Vice President – Finan ce and Chief Financial Officer The Sherwin-Williams Company 101 Prospect Avenue, N.W. Cleveland, Ohio 44115-1075

RE: Form 10-K for the Fiscal Year ended D ecember 31, 2005 Form 10-Q for the Fiscal Quarters ended March 31, 2006, June 30, 2006 and September 30, 2006 File No. 1-4851

Dear Mr. Hennessy:

We have completed our review of your Fo rm 10-K and related filings and have no further comments at this time.

If you have any questions regardi ng these comments, please direct them to Gus Rodriguez, Staff Accountant, at (202) 551-3752 or, in his absence, Rufus Decker, the undersigned, at (202) 551-3769.

Sincerely,
R u f u s D e c k e r
B r a n c h C h i e f

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

December 1, 2006

Mr. Sean P. Hennessy
Senior Vice President – Finan ce and Chief Financial Officer
The Sherwin-Williams Company
101 Prospect Avenue, N.W.
Cleveland, Ohio 44115-1075

 RE:  Form 10-K for the Fiscal  Year ended D ecember 31, 2005
                     Form 10-Q for the Fiscal Quarters  ended March 31, 2006, June 30,
  2006 and September 30, 2006
                     File No. 1-4851

Dear Mr. Hennessy:

We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time.

        If you have any questions regardi ng these comments, please direct them to Gus
Rodriguez, Staff Accountant, at (202) 551-3752 or, in his absence, Rufus Decker, the
undersigned, at (202) 551-3769.

          Sincerely,

        R u f u s  D e c k e r
        B r a n c h  C h i e f

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