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October 20, 2006

Mr. Rufus Decker

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E., Stop 7010

Washington, D.C. 20549

Re:          Carlisle
Companies Incorporated

Form 10-K for Fiscal Year Ended December 31, 2005

Forms 10-Q for the Fiscal Quarters Ended March 31, 2006 and June 30, 2006

File No. 1-9278

Dear Mr. Decker:

This letter is
submitted by Carlisle Companies Incorporated (“Carlisle” or the “Company”) in
response to comments of the staff of the Division of Corporate Finance of the
Securities and Exchange Commission (“SEC”) as set forth in your letter dated September
27, 2006 relating to the Company’s Form 10-K for the fiscal year-ended December
31, 2005 (the “2005 Form 10-K) and the Company’s Forms 10-Q for the fiscal
quarters ended March 31, 2006 and June 30, 2006 (the “2006 Forms 10-Q).

For your convenience, the
text of your letter has been reproduced below with the response to each
numbered comment set forth immediately below the comment.

FORM 10-K FOR THE YEAR ENDED DECEMBER
31, 2005

Financial Statements

Note 20 – Segment Information,
page 74

1.             We have reviewed your
response to comment two from our letter dated August 3, 2006.  It still remains unclear to us how you
determined that each of your businesses do not constitute your operating
segments.  Specifically, we note the
following:

·      You have reorganized your
business into three operating groups or segments managed by three Group
Presidents.  However, your Diversified Products
segment is comprised of six unrelated businesses including specialty trailer;
wire and cable; refrigerated truck body; brakes; and food service products.  It is not clear to us how you determined that
these unrelated businesses should be grouped into one segment.  It is also not clear how you managed all of
these unrelated businesses together without

examining each individual
business separately and discreetly.
Paragraph 13 of SFAS 131 indicates that if the CODM uses more than one
set of segment information, other factors may identify a single set of segment
information, other factors may identify a single set of components as
constituting an enterprise’s operating segments, including the nature of the
business activities of each activity, the existence of segment managers and
information presented to the board of directors.  The existence of managers responsible for
segments is only one of the criteria for defining operating segments.  The nature of the business activities of each
business and the information that you present to your Board of Directors should
weight significantly on your decision of what constitutes an operating
segment.  In your case, the nature of the
business activity is integral to identifying a single set of components as your
operating segments.  To the extent that
your higher level segment information (ie. three operating segments) is
represented by components that contain essentially dissimilar activities, while
the lower level components (ie. your individual businesses) contain similar
business activities, the lower level may be more representative of your
operating segments.  Based on the
information you have provided, it appears that your businesses may constitute
your operating segments.

·      The information that you
present to your Board of Directors is also integral to identifying your
operating segments.  We have reviewed the
reports that you provided in response to our previous comments including your
monthly Board of Director Reports, Financial Reports, Group President Reports
and Segment Reports.  We noted that all
of your reports include information at the business level.  These reports are reviewed by your CODM,
Board and Group Presidents on a monthly basis.
You indicate that the distribution of the reports is not indicative of
how you manage your operation.  However,
you have not provided any overwhelming evidence to suggest that you are not
managed by business.  Based on the
financial information provided to your CODM and Board, it would appear that
your enterprise is being managed at the business level and your businesses
appear to be your reportable operating segments.

After consideration of the above, it appears that your businesses
constitute your operating segments.
Therefore, please amend your Form 10-K for year ended December 31, 2005
and any subsequent filings on Form 10-Q accordingly.  Specifically, it appears that each of your
businesses in your Diversified Components segment should be separately
presented, except to the extent that they meet the aggregation criteria and
quantitative thresholds in paragraph 17 through 18 of SFAS 131.  If you believe that any business qualifies
for aggregation with another business, please tell us how you reached that
conclusion.

It is still Carlisle’s position
that the three reporting segments presented in the Company’s 2005 Form 10-K and
2006 Forms 10-Q properly reflects how Carlisle manages its businesses, the
requirements of SFAS 131 and is in accordance with Generally Accepted
Accounting Principles; however, in consideration of the SEC’s comments with
respect to the Diversified Components segment, we propose expanding Carlisle’s reporting
segments as described on the following pages.
We respectfully note that the changes proposed herein to Carlisle’s
segmentation are subject to review by the Company’s board of directors and
external auditors.  Management will meet
with the board of directors in November to review these proposed changes prior
to filing the Company’s Form 10-Q for the quarter ended September 30, 2006.  Management will also present this proposed
segmentation to Ernst & Young for their review and consideration.

Carlisle proposes the division of
the Diversified Components segment into the Specialty Products segment, the
Transportation Products segment and the General Industry segment (the “All
Other Category”).  The following table
presents the proposed segmentation and the respective percentage of
consolidated revenues, earnings before interest and income taxes (“EBIT”) and
assets for each segment:

  Segment

  % of Estimated 2006

  Revenues

  % of Estimated 2006

  EBIT

  % of Estimated

  2006 Assets

  Construction
  Materials

  43

  %

  54

  %

  37

  %

  Industrial
  Components

  30

  %

  20

  %

  34

  %

  Specialty
  Products (braking products)

  7

  %

  7

  %

  10

  %

  Transportation
  Products (specialty trailers)

  7

  %

  10

  %

  3

  %

  General Industry - All Other
  Category (wire and cable, refrigerated truck bodies, and foodservice
  products)

  13

  %

  9

  %

  16

  %

In
accordance with paragraph 20 of SFAS 131, total external revenues for the
reportable segments must equal or exceed 75% of total consolidated
revenue.  Based on estimated sales
revenues for the fiscal year ended December 31, 2006, the above segmentation identifies
87% of total revenues in reportable segments.
Of the businesses included in the General Industry segment or All Other
category, no business exceeds 10% of consolidated revenues, 10% of EBIT, or 10%
of total assets applying the quantitative thresholds specified in paragraph 18
of SFAS 131.  These General Industry
segment businesses also do not share a majority of the aggregation criteria
with another operating segment.  The
Company’s proposed segmentation meets the financial threshold criteria

when
applied to the Company’s results for the year ended December 31, 2005 and all
subsequent periods reported.

Notwithstanding
that Carlisle continues to believe that the Diversified Components segment, as
previously disclosed, meets the definition of a reporting segment, it is
management’s assessment that the only Diversified Components segment businesses
that meet the quantitative thresholds for separate reporting are the Company’s brake
business and specialty trailer business.
Prior to Carlisle’s change in reporting segmentation in November 2005,
the brake business was reported as the Specialty Products segment, and the specialty
trailer business was reported as the Transportation Products segment.  The wire and cable, refrigerated truck bodies
and foodservice businesses were reported in the General Industry segment.  The proposed segmentation presented in the
table returns Carlisle to its segmentation prior to the November 2005
management restructuring.

Carlisle
proposes the following steps to affect this change in its reporting segments:

·      The Company’s news release announcing the 2006 third quarter earnings
results will include sales and earnings for each of the segments presented in
the table.

·      The Company’s notes to the financial statements and Management’s
Discussion and Analysis for the Form 10-Q for the quarter ended September 30,
2006 will reflect the required information for each of the segments identified
in the table.

·      The Company’s notes to the financial statements and Management’s
Discussion and Analysis for the 2006 Form 10-K will reflect the required
information for each of the segments, including restating prior periods in
accordance with paragraph 34 of SFAS 131.

·      The Segment Information
note will include a segment financial data table that will include sales, EBIT,
assets, depreciation and amortization, and capital spending for the segments
for the years ended December 31, 2006, 2005 and 2004.

·      The Company
will make available on its website at www.carlisle.com the quarterly
sales and EBIT for each of these segments for 2006, 2005 and 2004.

If you have any questions, you may reach Carol Lowe at
704-501-1106 or Steven Ford at 315-477-9108.

Sincerely,

  /s/ Carol P. Lowe

  /s/ Steven J. Ford

  Carol P. Lowe

  Steven J. Ford

  Vice President and

  Chief Financial Officer

  Vice President, Secretary and

  General Counsel