SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

August 30, 2010

Mr. Steven J. Ford Vice President and Chief Financial Officer Carlisle Companies Incorporated 13925 Ballantyne Corporate Place, Suite 400 Charlotte, NC  28277
 RE: Carlisle Companies Incorporated
Form 10-K for the Fiscal Ye ar ended December 31, 2009
Forms 10-Q for the Fiscal Quarters ended March 31, 201 0 and June 30,
2010
  Schedule 14A filed on March 18, 2010
  File No. 1-9278

Dear Mr. Ford:
We have reviewed your response letter dated August 19, 2010 and have the
following additional comment.  In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comment applie s to your facts and circumstances or do not believe an
amendment is appropriate, please tell us why in your response.
 After reviewing the information you provide in response to this comment, we may
have additional comments.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2009

Item 8 – Financial Statements and Supplementary Data, page 37

Note 2 – Fire Gain, page 46

1. We have reviewed your response to prior comment 6 from our letter dated July
23, 2010.  You indicate that during the first six months of 2009 you received
$11.5 million of cash proceeds in connection w ith inventory destroyed by the fire
and $43 million of cash proceeds based on a negotiated settlement related to destroyed property, plant and equipment a nd fire-related clean -up costs.  We
believe that insurance settlements should be classified based on the nature of the insurance coverage that gave  you the right to receive payment.  As such, it is not

Mr. Steven J. Ford
Carlisle Companies Incorporated August 30, 2010 Page 2 of 2
clear from your response how you determin ed that classifying the entire amount
of these proceeds within cash flows from  operating activities was appropriate.
For example, we would anticipate that the insurance proceeds related to destroyed
property, plant and equipment would be classified within cash flows from
investing activities.  Please advise.  If after reassessing, you now believe that a
portion of the insurance proceeds should have been included within cash flows from investing activities, please show us in your supplemental response how you
will reflect the change in your next Fo rm 10-Q and Form 10-K.  We anticipate
that a footnote would clearly disclose the revision and the amounts now allocated
to each category of the statement of cash flows along with the previous allocation.
Please show us supplementally what your revised disclosures will look like.

*    *    *    *

You may contact Dorine Mill er, Financial Analyst, at  (202) 551-3711 or, in her
absence, Andrew Schoeffler, Staff Attorney, at (202) 551-3748 if you have any questions regarding legal or disclosure matters.  Pleas e contact Jeffrey Gordon, Staff Accountant, at
(202) 551-3866 or, in his absence, the undersigned at (202) 551-3769 if you have
questions regarding comments on the financia l statements and related matters.

 Sincerely,
 Rufus Decker
 Accounting Branch Chief