SecProbe.io

March 18, 2020
Richard Dierker
Executive Vice President and Chief Financial Officer
CHURCH & DWIGHT CO INC
500 Charles Ewing Boulevard
Ewing, NJ 08628
Re:CHURCH & DWIGHT CO INC
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 18, 2020
File No. 001-10585
Dear Mr. Dierker:
            We have limited our review of your filing to the financial statements and related
disclosures 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 comment 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 our comment applies to your facts
and circumstances, please tell us why in your response.  After reviewing your response to
this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies and Estimates
Impairment of goodwill, trade names and other intangible assets, page 34
1.We note that due to recent sales and profit declines, a significant portion of the excess
between fair value and the carrying value of certain of your personal care trade names has
eroded.  To help inventors more fully understand the potential impairment risk associated
with these assets, please identify each material trade name with a fair value that is not
substantially in excess of its carrying value and disclose the following:
•the carrying value and the percentage by which fair value exceeded carrying value;
and
•describe the variables underlying your “relief from royalty” and/or “excess earnings”
discounted cash flows such that changes in those variables may result in a decline in
fair value significant enough to trigger an impairment charge for the trade name.
Refer to Section V of Release 33-8350.

 FirstName LastNameRichard Dierker
 Comapany NameCHURCH & DWIGHT CO INC
 March 18, 2020 Page 2
 FirstName LastName
Richard Dierker
CHURCH & DWIGHT CO INC
March 18, 2020
Page 2
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences