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May 15, 2023
Kevin P. Zdimal
Chief Financial Officer
Carlisle Companies Inc.
16430 North Scottsdale Road, Suite 400
Scottsdale, Arizona 85254
Re:Carlisle Companies Inc.
Form 10-K, as amended, for the Fiscal Year Ended December 31, 2022
Filed February 22, 2023
File No. 001-09278
Dear Kevin P. Zdimal:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Annual Report on Form 10-K/A, Amendment No. 1, for the year ended December 31, 2022.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Consolidated Results of Operations, page 20
1.Where you describe two or more business reasons that contributed to a material change in
a financial statement line item between periods, please quantify, where possible, the extent
to which each factor contributed to the overall change in that line item.  In addition, when
you discuss revenue fluctuations, specifically describe the extent to which changes are
attributable to changes in prices or to changes in the volume or amount of goods or
services being sold or to the introduction of new products or services.  Please apply this
comment to both your consolidated and segment results of operations.  As an example,
your disclosures on page 20 attribute the increase in revenues to positive pricing across all
segments, contributions from an acquisition, and higher sales volumes, partially offset by
unfavorable foreign currency impacts.  See Item 303 of Regulation S-K, including Item
303(b)(2), and SEC Release No. 33-8350.

 FirstName LastNameKevin P. Zdimal
 Comapany NameCarlisle Companies Inc.
 May 15, 2023 Page 2
 FirstName LastNameKevin P. Zdimal
Carlisle Companies Inc.
May 15, 2023
Page 2
Liquidity and Capital Resources
Sources and Uses of Cash and Cash Equivalents, page 26
2.Please provide a more informative discussion and analysis of cash flows from operating
activities, including changes in working capital components, for the periods presented.  In
doing so, explain the underlying reasons and implications of material changes between
periods to provide investors with an understanding of trends and variability in cash flows.
Also ensure that your disclosures are not merely a recitation of changes evident from the
financial statements.  Please refer to Item 303(a) of Regulation S-K and SEC Release No.
33-8350.
Critical Accounting Estimates
Revenue Recognition, page 31
3.Within the last bullet of this section, you disclose that critical judgments and estimates
related to revenue recognition for certain customer contracts includes the measurement of
revenue "using the key inputs of expected gross margin and inventory in our possession."
Please tell us and revise your disclosures to clarify what this bullet is intending to convey.
To the extent this disclosure pertains to accounting for performance obligation satisfied
over time, ensure you provide the disclosures required by ASC 606-10-50-18.
Note 17 - Commitments and Contingencies
Litigation, page 74
4.Please address the following comments related to your asbestos-related claims:

•We note your disclosure that you "may recognize expenses for indemnity and defense
costs in particular periods if and when it becomes probable that such costs will not be
covered by insurance."  As this disclosures suggests that you may not record
litigation expense if covered by insurance, please clarify for us whether or not you
separately account for and record litigation accruals and insurance recoveries on a
gross basis.

•Tell us where on the balance sheet you classify litigation-related insurance
receivables and contingency accruals.  If presented on a net basis, tell us how the
balances meet the right of setoff criteria specified in ASC 210-20-45-1.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.

 FirstName LastNameKevin P. Zdimal
 Comapany NameCarlisle Companies Inc.
 May 15, 2023 Page 3
 FirstName LastName
Kevin P. Zdimal
Carlisle Companies Inc.
May 15, 2023
Page 3
            You may contact Beverly Singleton at (202) 551-3328 or Andrew Blume at (202) 551-
3254 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing