SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

                                                                February 7, 2012
 Via Facsimile

Mr. Steven J. Ford
Chief Financial Officer Carlisle Companies Incorporated 13925 Ballantyne Corporate Place, Suite 400 Charlotte, North Carolina 28277
 RE: Carlisle Companies Incorporated
Form 10-K for the Year Ended December 31, 2010
Filed February 16, 2011 Form 10-Q for the Period Ended September 30, 2011 Filed October 25, 2011 Response dated February 3, 2012 File No. 1-9278

Dear Mr. Ford:

We have reviewed your response letter date d February 3, 2012 and have the following
comment.  In our comment, we may ask you to pr ovide 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 applies to your facts a nd circumstances, 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, 2010

 Financial Statements

 Note 17 - Commitments and Contingencies, page 76

 Litigation, page 77

 1. We note your response to comment two from our  letter dated January 31, 2012.  You indicate
that the ultimate outcome of the U.S. I mmigration and Customs Enforcement Office of
Investigations will not be material.  Please co rrespondingly clarify your di sclosures to state,

Mr. Steven J. Ford
Carlisle Companies Incorporated February 7, 2012 Page 2
 if true, that the ultimate outcome of other lega l actions will not be material to your results of
operations rather than stati ng that the ultimate outcome may have more than an
inconsequential impact on your results of operations.  Please show us supplementally what
your revised disclosures will look like.

You may contact Ernest Greene, Staff Acc ountant at (202) 551- 3733 or Nudrat Salik,
Staff Accountant at (202) 551-3692 if you ha ve questions regarding this comment.
         S i n c e r e l y ,

/s/ Rufus Decker
         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