SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                                             August 3, 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 your letter dated July 25, 2006 and have the following
comments.  Where indicated, we think you should revise your disclosures in response to
these comments.  If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requir ements and to enhance the
overall disclosure in your filing.  We look forw ard to working with you in these respects.
We welcome any questions you may have about our comments or on a ny other aspect of
our review.  Feel free to call us at the phone numbers listed below.

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

General

1. In connection with responding to our comments, please provide, in writing, a statement acknowledging that:
• you are responsible for the adequacy and accuracy of the disclosure in your
 filings;
• staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• you may not assert staff comments as a de fense in any proceeding initiated by
the Commission or any person under the fe deral securities laws of the United
States.

Ms. Carol P.  Lowe
August 3, 2006
Page 2

Financial Statements

Note 20 – Segment Information, page 74

2. We reviewed the reports you provided us in response to comment four.  Your
monthly Board of Director Reports, Financial Reports, and Segment Reports as
well as your financial information provi ded at Board of Directors meetings
indicate that your chief operating deci sion maker regularly reviews discreet
financial information by business.  In addi tion, your monthly financial reports that
are distributed to the President and CEO and Group Presidents provide quick
summaries that include key information such as sales, gross profit, SG&A
expense, R&D expense, operating income, EBIT and net earnings by each
individual business.  In your Form 8-K filed on July 25, 2006 reporting your
second quarter 2006 results, your press re lease consistently  discusses the
performance in your various businesses in cluding but not limited to the tire and
wheel business, high-performance wire a nd cable business, specialty trailer
business, brake business and refrigerated truck body business.  Based upon the information you have provided us, it appears that each of your businesses constitute your operating segments.  Accordingly, please provide us with an
aggregation analysis under paragraph 17 of SFAS 131.  In doing so, please be
sure to explain to us in detail how you concluded that each individual business
aggregated with another business met the criteria in paragraph 17 to be
aggregated.  If, after further analysis, you conclude that some of your reportable
segments need to be broken into more reportable segments, please provide us with
your new proposed segment reporting structure as well.

*    *    *    *

Please respond to these comments within  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.

Ms. Carol P.  Lowe
August 3, 2006
Page 3

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