SEC Company Response from ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706) (ESE) — Apr 21, 2010

ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706)
Date: April 21, 2010 · CIK: 0000866706 · Accession: 0000866706-10-000014

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Referenced dates: March 4, 2010

Date

September 30, 2009

Author

/s/ Gary

Form

CORRESP

Company

ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706)

Letter

Division of Corporation Finance Securities and Exchange Commission File No. 1-10596 Form 10-K for the Fiscal Year Ended September 30, 2009 Filed November 30, 2009

RE: ESCO Technologies Inc.

Dear Ms. Krebs:

The attachment to this letter sets forth the response of ESCO Technologies Inc. to the comment letter of the Division of Corporation Finance of the Securities and Exchange Commission dated April 15, 2010, with respect to the above referenced filing. We have duplicated the comment set forth in the comment letter in the attachment and have provided our response.

If you have any questions or if you require additional information, please do not hesitate to contact me at 314-213-7246.

Sincerely,
/s/ Gary
E. Muenster

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CORRESP
1
filename1.htm

    escocorrespon21apr10.htm

    April 21,
2010

    Ms.
Kathleen Krebs

    Special
Counsel

    Division
of Corporation Finance

    Securities
and Exchange Commission

    Washington,
D.C. 20549

    RE:           ESCO
Technologies Inc.

    File No. 1-10596

    Form 10-K for the Fiscal Year Ended
September 30, 2009

    Filed November 30, 2009

    Dear Ms.
Krebs:

    The
attachment to this letter sets forth the response of ESCO Technologies Inc. to
the comment letter of the Division of Corporation Finance of the Securities and
Exchange Commission dated April 15, 2010, with respect to the above referenced
filing.  We have duplicated the comment set forth in the comment
letter in the attachment and have provided our response.

    If you
have any questions or if you require additional information, please do not
hesitate to contact me at 314-213-7246.

    Sincerely,

    /s/ Gary
E. Muenster

    Gary E.
Muenster

    Executive
Vice President

    and Chief
Financial Officer

    ESCO
Technologies Inc.

    9900A
Clayton Road

    St.
Louis, MO  63124

    Compensation Consultant and
Market Checking, page 9 of the Proxy Statement (comment #1):

    We
note your response to comment seven in our letter dated March 4, 2010, and are
unable to agree that the composite surveys do not need to be
disclosed.  As previously stated, Item 402 of Regulation S-K requires
you to identify the component companies used for benchmarking
purposes.  As you are using these surveys for benchmarking purposes,
you must identify each company included in the surveys by name, regardless of
the size of the benchmarking list.  Please confirm that you will
identify all companies used for benchmarking purposes in future
filings.

    Response

    We
confirm we will identify all the component companies used for benchmarking
purposes in future filings.

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