SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

September 2, 2008

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

 RE: Form 10-K for the fiscal  year ended December 31, 2007
  Form 10-Q for the pe riod ended June 30, 2008
  File No. 1-9278

Dear Ms. Lowe:

We have reviewed these filings and 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.

General

1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.  These revisions should be included in your future filings.

10-K FOR THE YEAR E NDED DECEMBER 31, 2007

Item 1.  Business, page 1

2. Please discuss the competitive conditions  information require d by Item 101(c)(1)(x)
of Regulation S-K.

Ms. Carol P. Lowe
September 2, 2008
Page 2 of 3
Description of Businesses by Reportable Segment

Construction Materials, page 3

3. Please identify the customer who represented 18% of this segment’s revenues pursuant to Item 101(c)(1)(vii) of Regulati on S-K.  Please also comply with this
comment for the Industrial Components cu stomer who accounted for 12% of that
segment’s revenues if their loss would be material.

Research and Development, page 9

4. Please discuss your research and development activities.

FORM 10-Q FOR THE PERIOD ENDED JUNE 30, 2008

Consolidated Statements of Earnings  and Comprehensive Income, page 2

5. Your disclosures on page 20 state that the other expense (income), net line item
includes a $4.7 million charge related to ma nagement and facilities transition of a
braking business in the United Kingdom and a sset charges related to closed facilities
of $2.0 million.  Please help us understand how  you determined it was appropriate to
exclude each of these items from your  determination of operating income.

Notes to the Financial Statements

Note 15.  Segment Information, page 16

6. Please disclose in your segment footnote the types of amounts included in your
determination of corporate expenses, corporate operating income, and corporate assets for each period presented.  Please also disclose why these amounts were not
allocated to the other reportable segments.  Please also discuss in MD&A the business
reasons for fluctuations in these amounts subsequent to your disc ussion of results of
operations by segment.

SCHEDULE 14A FILED ON FEBRUARY 29, 2008

Compensation Discussion and Analysis, page 17

7. Please provide the information required by Item 402(b)(1)(xv) of  Regulation S-K.

*    *    *    *

Ms. Carol P. Lowe
September 2, 2008
Page 3 of 3
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 supplemental 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 filings reviewed by the staff to be certain that they have provided all information required under the Securities Ex change Act of 1934 and that they have
provided all information investors require fo r an informed decision.  Since the company
and its management are in possession of all f acts relating 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 comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities 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 Errol Sanderson, at ( 202) 551-3746 or, in his absence, Jennifer
Hardy, Legal Branch Chief, at (202) 551-3767 if you have any questions regarding legal
matters.  Please contact Nudr at Salik, Staff Accountant, at (202) 551-3692 or, in her
absence, the undersigned at (202) 551-3769 if  you have questions regarding comments on
the financial statements and related matters.

       S i n c e r e l y ,

       R u f u s  D e c k e r
       A c c o u n t i n g  B r a n c h  C h i e f