SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                                             May 18, 2006

Ms. Carol P. Lowe
Vice President and Chief Financial Officer
Carlisle Companies Incorporated
13925 Ballantyne Corporate Place, Suite 400
Charlotte, North Carolina 28277

 RE: Form 10-K for Fiscal Ye ar Ended December 31, 2005
File No. 1-9278

Dear Ms. Lowe:

  We have reviewed these filings a nd have the following comments.  If you
disagree with a comment, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.  After reviewing this information, we may
or may not raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2005

General

1. Where a comment below requests additional disclosures or other revisions, please
show us in your response what the revi sions will look like.  These revisions
should be included in your future filings, including your interim filings, where appropriate.

Ms. Carol P.  Lowe
May 18, 2006
Page 2

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

2005 Compared to 2004

Consolidated Results of Continuing Operations, page 20

2. You indicate that your gross margin was impacted by increased selling prices offset by higher raw material costs, lower production resulting in increased
unabsorbed overhead, certain production ine fficiencies and incr ease freight and
utility costs.  Please discuss these business reasons for the changes between periods in your total gross profit in greater detail.  Wh ere there is more than one
business reason for any change discusse d in MD&A, please attempt to quantify
the incremental impact of each individual business reason discussed.  Please show
us what your revised MD&A for 2005 compared to 2004 will look like.  See Item
303(a)(3) of Regulation S-K and Fi nancial Reporting Codification 501.04.

3. You indicate that the majority of the increase in selling and administrative
expenses was attributable to variable expe nses associated with increased sales.
Please disclose whether, or not you expect  this trend to continue.  Please also
disclose and discuss in gr eater detail the types of selling and administrative
expenses that are variable and increase proportional to sales.

Financial Statements

Note 1 – Summary of Significant Accounting Policies

Inventories, page 48

4. You should use one inventory method for similar types of inventories.  A mixture of methods should only be used for differe nt types of inventories, particularly
when there are valid business reasons fo r doing so.  Please disclose which types
of inventory you use each method for.  Please disclose whether you use both
methods for any similar types of inventory.  If so, please also  disclose your basis
for doing this.  In a portion of these instances, this may be due to the LIFO method being used for similar types of inventory in countries that permit the
LIFO method and the FIFO method may be used in countries that do not permit
the use of the LIFO method.  If this is the case for some of your inventory, please
also disclose the foreign countries with similar inventory categories that you use
the FIFO method in.

Note 14 – Income Taxes, page 67

5. Please separately disclose the amounts and expiration dates of operating loss
carryforwards, foreign tax credits and alternative minimum tax credit
carryforwards.  Please refer to paragraph 48 of SFAS 109.

Ms. Carol P.  Lowe
May 18, 2006
Page 3

Note 20 – Segment Information, page 74

6. You reorganized your previously reported  five operating segments into three
operating segments.  It appears that  you have aggregated your former
transportation products, specialty products and general industry (all other) segments into the Diversified Components segment while your automotive
products segment has been discontinued.  We  realize that we asked you about this
subject about two years ago;  however, you have made certain acquisitions in the
subsequent period which may have impacted your segment analysis.  Please tell us how you determined that each of the operating segments in the Diversified
Components segment have similar ec onomic characteristics as required by
paragraph 17 of SFAS 131 for aggregation.  Please also provide us with your
aggregation analysis for the operating se gments in the Industrial Components
segment as well.  In doing so, please address any apparent differences in
economic characteristics and trends be tween each segment being aggregated.
Please provide us with your key metrics us ed in your quantitati ve analysis for at
least each of the last five fiscal years,  the most recent interim periods, and each
subsequent year and interim period fo r which you have budgeting information.
Please ensure that you also show the dollar and percenta ge changes from period to
period in your analysis.  Please include detailed explanations for any apparent
differences in economic characteristics and trends for a given operating segment
when compared to another operating segm ent for a given period or over several
periods.  Including graphs in your supplem ental response would also be helpful
for trend analysis of operating segments aggregated in each reportable segment.
Explain why each of these differences woul d not be considered an indication of
differences in economic characteristics between the two operating segments and
your basis for concluding that each di fference was only temporary.  Refer to
paragraphs 17 to 20 of SFAS 131 a nd Question 8 of the FASB Staff
Implementation Guide for SFAS 131.

*    *    *    *

  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its

Ms. Carol P.  Lowe
May 18, 2006
Page 4

management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in
their filings;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Ernest Greene, Staff A ccountant, at (202) 551-3733, or in his
absence, the undersigned, at (202) 551-3769, if  you have questions regarding comments
on the financial statements and related matters.

  Sincerely,

        R u f u s  D e c k e r
       Accounting Branch Chief