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SEC Company Response from WHIRLPOOL (WHR) — Nov 21, 2005

WHIRLPOOL CORP /DE/ (WHR) (CIK 0000106640)
Date: Nov. 21, 2005 · CIK: 0000106640 · Accession: 0001047469-05-027231

AI Filing Summary & Sentiment

File numbers found in text: 333-128686

Date
November 21, 2005
Author
WHIRLPOOL CORPORATION
Form
CORRESP
Company
WHIRLPOOL CORP /DE/ (WHR) (CIK 0000106640)

Letter

WHIRLPOOL CORPORATION

2000 North M-63

Benton Harbor, Michigan 49022-2692

November 18,

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:Whirlpool Corporation

Form S-4 Registration Statement (File No. 333-128686)

Ladies and Gentlemen:

Whirlpool Corporation (the "Company") hereby respectfully requests that the effective date of the Company's Registration Statement on Form S-4 (File No. 333-128686) (as amended through the date hereof, the "Registration Statement") be accelerated so that it becomes effective at 10:00 a.m., Eastern Time, on Monday, November 21, 2005 or as soon as reasonably practicable thereafter.

The Company hereby acknowledges the following:

1.Should the Securities and Exchange Commission (the "Commission") or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

2.The action of the Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

3.The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed public offering of the securities specified in the Registration Statement.

Please call Ellen J. Odoner at (212) 310-8438 or Cinthia J. Trajtenberg at (212) 310-8074 of Weil, Gotshal & Manges LLP to confirm the effectiveness of the Registration Statement.

Very truly yours,
WHIRLPOOL CORPORATION

Show Raw Text
CORRESP
1
filename1.htm

WHIRLPOOL CORPORATION

2000 North M-63

Benton Harbor, Michigan 49022-2692

November 18,
2005

Division
of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:Whirlpool
Corporation

Form S-4 Registration Statement (File No. 333-128686)

Ladies
and Gentlemen:

        Whirlpool
Corporation (the "Company") hereby respectfully requests that the effective date of the Company's Registration Statement on Form S-4 (File
No. 333-128686) (as amended through the date hereof, the "Registration Statement") be accelerated so that it becomes effective at 10:00 a.m., Eastern Time, on Monday,
November 21, 2005 or as soon as reasonably practicable thereafter.

        The
Company hereby acknowledges the following:

1.Should
the Securities and Exchange Commission (the "Commission") or the staff of the Commission, acting pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

2.The
action of the Commission or the staff of the Commission, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

3.The
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

        The
Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to
the proposed public offering of the securities specified in the Registration Statement.

        Please
call Ellen J. Odoner at (212) 310-8438 or Cinthia J. Trajtenberg at (212) 310-8074 of Weil, Gotshal & Manges LLP to confirm the
effectiveness of the Registration Statement.

Very truly yours,

WHIRLPOOL CORPORATION

By:

/s/  DANIEL F. HOPP

Name:

Daniel F. Hopp

Title:

Senior Vice President, Corporate Affairs and General Counsel