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SEC Comment Letter for SHERWIN WILLIAMS CO (SHW) (CIK 0000089800) (SHW) — Jun 27, 2011

SHERWIN WILLIAMS CO (SHW) (CIK 0000089800)
Date: June 27, 2011 · CIK: 0000089800 · Accession: 0000000000-11-039101

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
June 27, 2011
Author
Rufus Decker
Form
UPLOAD
Company
SHERWIN WILLIAMS CO (SHW) (CIK 0000089800)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE June 27, 2011 Via E-mail Mr. Sean P. Hennessy Chief Financial Officer The Sherwin-Williams Company 101 West Prospect Avenue Cleveland, Ohio 44115-1075 RE: The Sherwin-Williams Company Form 10-K for the Year Ended December 31, 2010 Filed February 23, 2011 Form 10-Q for the Period Ended March 31, 2011 Filed April 26, 2011 Definitive Proxy Statement on Schedule 14A Filed March 9, 2011 File No. 1-4851

Dear Mr. Hennessy:

We have reviewed your filings and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter with in 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provi de in response to this comment, we may have additional comments. Form 10-K for the Year Ended December 31, 2010

Exhibit 13 – Annual Report

Note 10 – Litigation, page 65

1. We have read your response to prior co mment five. In future filings, please expand your disclosures in a similar manne r to your response to state that it is

Mr. Sean P. Hennessy The Sherwin-Williams Company June 27, 2011 Page 2 not possible to estimate the range of r easonably possible losses as it relates to the public nuisance claim litigation.

You may contact Era Anagnosti, Sta ff Attorney, at (202) 551-3369 or Dietrich King, Staff Attorn ey at (202) 551-3338 if you have any questions regarding legal matters. Please contact Ernest Green e, Staff Accountant at (202) 551-3733 or me at (202) 551-3769 if you have questions regarding comments on the financial statements and related matters. Sincerely, / s / R u f u s D e c k e r R u f u s D e c k e r Accounting Branch Chief

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

                                                                              June 27, 2011
 Via E-mail

Mr. Sean P. Hennessy Chief Financial Officer The Sherwin-Williams Company 101 West Prospect Avenue Cleveland, Ohio 44115-1075
 RE: The Sherwin-Williams Company
Form 10-K for the Year Ended December 31, 2010
Filed February 23, 2011 Form 10-Q for the Period Ended March 31, 2011 Filed April 26, 2011 Definitive Proxy Statement on Schedule 14A  Filed March 9, 2011 File No. 1-4851

Dear Mr. Hennessy:

We have reviewed your filings and have the following comment.  In our
comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter with in 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 comment applies to your  facts and circumstances,
please tell us why in your response.     After reviewing the information you provi de in response to this comment, we
may have additional comments.  Form 10-K for the Year Ended December 31, 2010

 Exhibit 13 – Annual Report

 Note 10 – Litigation, page 65

1. We have read your response to prior co mment five.  In future filings, please
expand your disclosures in a similar manne r to your response to state that it is

Mr. Sean P. Hennessy
The Sherwin-Williams Company June 27, 2011 Page 2
 not possible to estimate the range of r easonably possible losses as it relates to
the public nuisance claim litigation.

You may contact Era Anagnosti, Sta ff Attorney, at (202) 551-3369 or
Dietrich King, Staff Attorn ey at (202) 551-3338 if you have  any questions regarding
legal matters.  Please contact Ernest Green e, Staff Accountant at (202) 551-3733 or
me at (202) 551-3769 if you have questions  regarding comments on the financial
statements and related matters.         Sincerely,          / s /  R u f u s  D e c k e r           R u f u s  D e c k e r
       Accounting Branch Chief