SecProbe.io

May 7, 2025
Patrick Hallinan
Chief Financial Officer
Stanley Black & Decker, Inc.
1000 Stanley Drive
New Britain, CT 06053
Re:Stanley Black & Decker, Inc.
Form 10-K for the Year Ended December 28, 2024
Form 10-Q for the Quarter Ended March 29, 2025
Response Letter dated April 29, 2025
File No. 001-05224
Dear Patrick Hallinan:
            We have reviewed your April 29, 2025 response to our comment letter and have the
following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Unless we note otherwise, any references to prior comments are to comments in our April 1,
2025 letter.
Form 10-K for the Year Ended December 31, 2025
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Certain Items Impacting Earnings, page 32
We note from your response to prior comment 2, that in 2024, the footprint
rationalization adjustment includes $45.2m of costs related to the transformation or re-
configuration of other sites within your manufacturing and distribution network. You
also state that these costs primarily related to inventory transfer costs and engineering
and information technology costs to re-configure the operations, processes, floorplans
or system functionality, as applicable by site, in order to integrate and globalize
product value streams within manufacturing centers of excellence and create an
integrated hub-and-spoke distribution model with strategically located regional sites 1.

May 7, 2025
Page 2
to reduce delivery times to customers.  Please explain to us why you believe these
costs do not represent normal recurring operating costs of the business. See guidance
in Question 100.01 of the C&DI on Non-GAAP Financial Measures.
 Additionally,  regarding the adjustment for accelerated depreciation in both 2024 and
2023, please explain to us the nature of the underlying assets, whether the assets
continue to be used in operations, and when you intend to retire the assets.
2.We note from your response to our prior comment 3 that the non-cash asset write-
downs of $44 million in 2023 included in footnote (1) related to tooling and inventory
(predominantly raw materials and WIP) driven primarily by the closure of the Fort
Worth, Texas manufacturing site.  Please note that it is not appropriate to adjust non-
GAAP financial measures for inventory charges as they represent normal, recurring
costs of operations.  Please revise future filings accordingly.
Form 10-Q for the Quarter Ended March 29, 2025
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 31
3.We note your summary of pre-tax Non-GAAP adjustments on page 33.  Please tell us
the nature of the costs included in the line item titled “Complexity Reduction
& Operational Excellence” and explain to us how they differ from Strategic Sourcing
& Operational Excellence costs.  Also, please explain to us why these are not
considered normal recurring operating costs of business.  See guidance in Question
100.01 of the C&DI on Non-GAAP Financial Measures.
            Please contact Claire Erlanger at 202-551-3301 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing