SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010

October 10, 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 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 your response lett er dated September 26, 2008 and have the
following additional comments.  If you disagree with our comment, we will consider
your explanation as to why our comment is inapplicable or a re vision is unnecessary.
Please be as detailed as nece ssary in your explanation.

 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, 2007

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.

Ms. Carol P. Lowe
October 10, 2008
Page 2 of 2
FORM 10-Q FOR THE PERIOD ENDED JUNE 30, 2008

Consolidated Statements of Earnings  and Comprehensive Income, page 2

2. We note your response to prior comment 5.  It remains unclear how you determined that the $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 should be excluded from your de termination of operating income.  We
remind you that paragraph 45 of SFAS 144 states  that a gain or loss recognized on the
sale of a long-lived asset that is not a component of an entity should be included in
the determination of operating income.  Pleas e clearly disclose th e nature of each of
these items, how you calculated each item, and your basis for excluding each item
from your determination of operating income.  Your explanation should address whether the brake business for which the $4.7 m illion charge is related to is the same
brake business which has been reported in discontinued operations based on your
disclosures on page 10.  If so, tell us what consideration you gave to reflecting the $4.7 million in discontinued operations pursuant to paragraphs 41 through 44 of SFAS 144.

*    *    *    *

  Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response.  Please pr ovide us with a supplemental response letter
that keys your responses to our comment s and provides any requested supplemental
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 reviewin g your responses to our comments.

  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