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Sean P. Hennessy

Senior Vice President – Finance

and Chief Financial Officer

Phone: 216-566-2573

June 22, 2010

By EDGAR and U.S. Mail

Rufus Decker

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 4631

100 F Street, NE

Washington, DC 20549-4631

    Re:

    The Sherwin-Williams Company

Form 10-K for fiscal year ended December 31, 2009

Form 10-Q for fiscal quarter ended March 31, 2010

File No. 1-4851

Dear Mr. Decker:

We have set forth below responses of The Sherwin-Williams Company (“Sherwin-Williams,” the
“Company” or the “Registrant”) to address the additional comments of the Staff of the Division of
Corporation Finance contained in your letter dated June 11, 2010 regarding your review of
Sherwin-Williams’ response letter dated June 8, 2010.

For your convenience, we have restated in boldface each of the Staff’s comments followed by our
response.

FORM 10-K FOR FISCAL  YEAR ENDED DECEMBER 31, 2009

Exhibit 13

General

    1.

    Comment: 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, including your interim filings, if
applicable.

The Sherwin-Williams Company     101 West Prospect Avenue, Cleveland, Ohio 44115

Mr. Rufus Decker

June 22, 2010

Page 2

    Response: Where a comment requests additional disclosures or other revisions, the
Registrant’s response includes an example of what the additional disclosures or revisions will
look like. The Registrant will include such additional disclosures or other revisions in its
future filings, including our interim filings, if applicable.

Management’s Discussion and Analysis

Results
of Operations, page 31

    2.

    Comment: We note your response to prior comment 4. We continue to believe that you
should further clarify the specific amounts that you are referring to in arriving at the $8.6
million change and where these amounts are recorded on your statements of consolidated income.
In arriving at this amount, it appears that you are looking at certain components of the
other general expense – net, interest and net investment income, and other expense (income) –
net line items. It is not clear how you determined which components to include and exclude.
In this regard, you could consider discussing each line item as presented on your statements
of consolidated income rather than discussing components of various line items. Your proposed
disclosure states that these amounts represent administrative expenses not directly associated
with reportable operating segments, which you define on page 13 as the Paint Stores Group,
Consumer Group, and Global Finishes Group. It appears that there would be additional
administrative expenses not directly associated with these reportable
operating segments, including
those reported under the Administrative segment. Please advise or revise your disclosure as
necessary.

    Response: In response to the Staff’s comments, in future filings the Registrant will
revise its analysis of results of operations in Management’s Discussion and Analysis to discuss
each line item as presented in the statements of consolidated income by operating segment. An
example of this revised presentation using the results of operations for the year ended December
31, 2009 compared to the year ended December 31, 2008 is as follows:

Consolidated net sales for 2009 decreased due primarily to volume declines resulting from
continuing weak U.S. and foreign economic conditions. One acquisition completed during 2009
and four acquisitions completed throughout 2008 increased consolidated net sales 0.5
percent. Unfavorable currency translation rate changes decreased 2009 consolidated net
sales 1.3 percent. Net sales of all consolidated foreign subsidiaries decreased 8.4 percent
to $1.03 billion for 2009 versus $1.12 billion for 2008. Of the decrease in net sales for
all consolidated foreign subsidiaries during 2009, 10.0 percent related to unfavorable
foreign currency translation rates. Net sales of all operations other than consolidated
foreign subsidiaries decreased 11.5 percent to $6.07 billion for 2009 versus $6.86 billion
for 2008.

Net sales in the Paint Stores Group in 2009 decreased primarily due to lower paint volume
sales that were partially offset by the remaining impact of 2008 selling price increases.
Net sales from
stores open for more than twelve calendar months decreased 12.9 percent for the full year.
During 2009, the Paint Stores Group opened 53 new stores and closed 45 redundant locations
for

The Sherwin-Williams Company     101 West Prospect Avenue, Cleveland, Ohio 44115

Mr. Rufus Decker

June 22, 2010

Page 3

a net increase of 8 stores, increasing the total number of stores in operation at
December 31, 2009 to 3,354 in the United States, Canada and the Caribbean. The Paint Stores
Group’s objective is to expand its store base an average of three percent each year,
primarily through internal growth. The percentage change in total paint sales volume was a
decrease in the mid-teens for the year over 2008 partially offset by impact of selling
price increases in the first half of 2008. Sales of products other than paint decreased
approximately 15.2 percent for the year over 2008. A discussion of changes in volume versus
pricing for sales of products other than paint is not pertinent due to the wide assortment
of general merchandise sold.

Net sales of the Consumer Group decreased due primarily to sluggish DIY demand at most of
the Group’s retail customers. Paint volume sales percentage change in the Consumer Group
compared to last year was a decrease in the mid-single digits. Sales of aerosols, brushes,
rollers, caulk and other paint related products decreased approximately 7.4 percent for the
year over 2008. A discussion of changes in volume versus pricing for sales of products
other than paint is not pertinent due to the wide assortment of paint-related merchandise
sold. The Consumer Group plans to continue its aggressive promotions of new and existing
products in 2010 and continue expanding its customer base and product assortment at
existing customers.

The Global Finishes Group’s net sales in 2009, when stated in U.S. dollars, decreased due
primarily to volume decreases and unfavorable currency translation rate changes partially
offset by selling price increases and acquisitions. Paint sales volume percentage decreased
in the mid-single digits. Acquisitions increased this Group’s net sales in U.S. dollars by
1.5 percent. Unfavorable currency translation rate changes in the year decreased net sales
by 4.8 percent for 2009. In 2009, the Global Finishes Group opened 18 new branches and
closed 20 locations for a net decrease of 2 branches decreasing the total to 539 branches
open in the United States, Mexico, Chile, Brazil, Canada, Uruguay, Argentina, Peru and
India at year-end. In 2010, the Global Finishes Group expects to continue expanding its
worldwide presence and improving its customer base.

Net sales in the Administrative segment, which primarily consist of external leasing
revenue of excess headquarters space and leasing of facilities no longer used by the
Company in its primary business, decreased by an insignificant amount in 2009.

Consolidated gross profit decreased $235.6 million related primarily to lower sales in
2009, but increased as a percent to net sales to 46.0 percent from 43.8 percent in 2008 due
primarily to selling price increases initiated over the past 18 months, cost control
efforts primarily in the Consumer Group and improved freight and other distribution costs
partially offset by incremental site closing costs and higher fixed costs related to
reduced manufacturing and distribution volume. The Paint Stores Group’s gross profit for
2009 decreased $163.2 million compared to 2008, but increased as a percent of sales by 3.5
percent due primarily to lower volume sales that were partially offset by higher selling
prices initiated in 2008. The Consumer Group’s gross profit increased $14.4 million for
2009 over 2008 due primarily to cost control efforts and reductions in freight and related
distribution costs partially offset by lower sales,
lower volume throughput in the manufacturing and distribution facilities and incremental
costs related to site closings. As a percent of sales, Consumer Group’s gross profit
increased by 3.2

The Sherwin-Williams Company     101 West Prospect Avenue, Cleveland, Ohio 44115

Mr. Rufus Decker

June 22, 2010

Page 4

percent. The Global Finishes Group’s gross profit for 2009 decreased $78.9
million and decreased as a percent of sales by 0.7 percent due primarily to decreased sales
volumes, unfavorable foreign currency translation exchange rate changes, and increased
manufacturing and distribution costs relating to lower production volumes. Acquisitions
increased Global Finishes Group’s gross profit by $9.3 million, or 32.3 percent of
acquisition net sales, and foreign currency translation rate fluctuations decreased gross
profit by $29.6 million for 2009. The Administrative segment’s gross profit decreased by
an insignificant amount.

SG&A decreased by $108.8 million due primarily to good expense control. Acquisitions added
$15.9 million of SG&A in 2009, representing 40.1 percent of acquisition net sales. SG&A
increased as a percent of sales to 35.7 percent in 2009 from 33.1 percent in 2008. In the
Paint Stores Group, SG&A decreased $75.9 million for the year due primarily to good SG&A
spending control partially offset by increased spending due to the number of new store
openings. The Consumer Group’s SG&A increased by $14.7 million for the year due to the
impact of acquisition SG&A of $4.3 million, or 39.7 percent of acquisition net sales, and
increased spending on customer programs. The Global Finishes Group’s SG&A decreased by
$22.1 million for the year relating primarily to foreign currency translation rate
fluctuations of $23.7 million and good SG&A spending control that was partially offset by
acquisition SG&A of $11.7 million, or 40.3 percent of acquisition net sales. The
Administrative segment’s SG&A decreased $25.5 million primarily due to a decrease of $13.6
million in non-compensatory administrative expenses and a decrease in compensation expense
of $8.2 million ($17.8 million decrease in stock-based compensation expense not directly
associated with the Reportable Operating Segments, partially offset by increases in
incentive compensation expense of $9.6 million).

In the Administrative segment, the Company recognized $23.3 million in total stock-based
compensation expense during 2009, $41.1 million in 2008 and $35.4 million during 2007.
Total unrecognized stock-based compensation expense was $50.3 million at December 31, 2009,
and recognition is expected to occur over a weighted-average period of 1.60 years. The
weighted-average risk-free rate for 2009 grants of 2.39 percent was based upon the U.S.
Treasury yield curve at the time of grant. The weighted-average expected life of options of
5.27 years for 2009 was calculated using a scenario analysis model that uses historical
data to aggregate the holding period from actual exercises, post-vesting cancellations and
hypothetical assumed exercises on all outstanding options. The weighted average expected
volatility of stock for 2009 of 31.9 percent was calculated using historical and implied
volatilities. The weighted average expected dividend yield of stock for 2009 of 2.69
percent was the Company’s best estimate of the expected future dividend yield using
historical activity and expectations about future activity. See Note 13, on pages 70 and 71
of this report, for more information concerning stock based compensation.

Other general expense – net increased $14.3 million in 2009 compared to 2008. The increase
was mainly caused by an increase of $18.9 million in the Administrative segment, primarily
due
to an increase in provisions for environmental matters of $17.8 million and a $2.4 million
increase in costs associated with exit or disposal activities. Partially offsetting the
increases in

The Sherwin-Williams Company     101 West Prospect Avenue, Cleveland, Ohio 44115

Mr. Rufus Decker

June 22, 2010

Page 5

the Administrative segment were insignificant changes in Other general expense
– net of the Reportable Operating Segments mainly related to decreases in net losses on the
disposition of assets. See Note 14, on page 72 of this report, for more information
concerning Other general expense – net.

Impairments of trademarks and goodwill decreased $40.5 million in 2009 compared to 2008.
As required by the Goodwill and Other Intangibles Topic of the ASC, management performed an
annual impairment test of goodwill and indefinite-lived intangible assets as of October 1,
2009. The impairment test in 2009 resulted in reductions in the carrying value of
trademarks with indefinite lives of $14.1 million and no reductions in value of goodwill.
The impairment charges are shown as a separate line in the Statements of consolidated
income in accordance with the Goodwill and Other Intangibles Topic of the ASC. The
impairment of trademarks with indefinite lives was charged to the Paint Stores Group ($11.0
million), the Global Finishes Group ($3.0 million), and the Consumer Group ($0.1 million).
The impairments related primarily to lower-than-anticipated projected sales of certain
acquired brands. See Note 5, on pages 51 through 53 of this report, for more information
concerning the impairment of intangible assets.

The $21.9 million Loss on dissolution of a foreign subsidiary in 2009 was a pre-tax expense
charged in the Global Finishes Group related to a European subsidiary that was dissolved in
the fourth quarter of 2009. See Note 3, on page 51 of this report, for more information
concerning the Loss on dissolution of a foreign subsidiary.

Interest expense, included in the Administrative segment, decreased $25.7 million in 2009
versus 2008 due primarily to decreased short-term borrowings at rates that were lower than
2008.

Interest and net investment income, primarily included in the Administrative segment,
decreased $1.5 million due to a lower level of short-term investments in 2009 when compared
to 2008 at lower overall rates. The net of the two combined for an overall decrease of
$24.1 million in the aggregate expense.

Other expense (income) – net fluctuated to $1.7 million income from $5.1 million expense in
2008. This change was due primarily to a decrease in unfavorable foreign currency related
transactions across all segments to a loss of $4.9 million in 2009 from a loss of $10.6
million in 2008. Partially offsetting the reduction in foreign currency transaction losses
was an increase in Net expense from financing and investing activities of $1.7 million
primarily in the Administrative segment and reduced dividend and royalty income of $1.1
million primarily in the Administrative Segment. An increase in other miscellaneous income
and expense items of $3.9 million, primarily in the Administrative segment, accounted for
the remaining fluctuation in Other expense (income) – net. See Note 14, on page 72 of this
report, for more information concerning Other expense (income) – net.

Consolidated Income before income taxes in 2009 decreased $91.7 million due primarily to a
decrease in gross profit of $235.6 million and the impact of a loss on dissolution of a
foreign subsidiary of $21.9 million partially offset by a decrease in selling, general and
administrative expenses of $108.8 million, a decrease in trademark and goodwill impairment
charges of $40.5

The Sherwin-Williams Company     101 West Prospect Avenue, Cleveland, Ohio 44115

Mr. Rufus Decker

June 22, 2010

Page 6

million, and a reduction of $16.6 million in interest