SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

MAIL STOP 3561

         May 27, 2010  Mr. Frederic Villoutreix Chief Executive Officer Schweitzer-Mauduit International, Inc. 100 North Point Center East Alpharetta, GA 30022-8246

Re: Schweitzer-Mauduit International, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2009
Filed March 8, 2010
 File No. 001-13948    Schedule 14A  Filed March 8, 2010
Dear Mr. Villoutreix:
 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some comments, we have asked you to provide us with additional information so we may
better understand your disclosure.  Please do so within the time fram e set forth below.
You should comply with the remaining comment s in all future filings, as applicable.
Please confirm in writing that you will do so and also explain to us how you intend to
comply, within the time frame set forth below.   Please understand that after our review of
all of your responses, we may raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Frederic Villoutreix
Schweitzer-Mauduit International, Inc.
May 27, 2010
Page 2

Form 10-K for Fiscal Year Ended December 31, 2009
 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 25
 1. We note your presentation of ‘net sales at constant currency’, ‘EPS excluding
restructuring and impairment expenses – d iluted,’ ‘EPS adjusted for share dilution,’
and ‘EBIT’ in your fourth quarter 2009 ear nings conference materials.  We further
note your presentation of ‘free cash flow’ in Ex. 99.1 to your February 10, 2010 Form
8-K.  These appear to be non-GAAP measur es as defined by Regulation G and Item
10(e) of Regulation S-K as they are not required by GAAP, Commission rules or
appear to be required by a syst em of regulation that  is applicable to the Company.  To
the extent you disclose or release publicly any material information that includes a
non-GAAP measure, you please label the m easures as non-GAAP and provide a
reconciliation to the most clearly comparable  GAAP measures.  Please confirm to us
that you will comply with the applicable non-GAAP requirements for any non-GAAP measures you provide in the future.
Results of Operations, page 30

 Year Ended December 31, 2009 Compared with the Year Ended December 31, 2008,
page 30
 Net Sales, page 30

 2. We note that you exited the Brazil coated pa pers business (page 31) and closed the
Lee Mills (page 61) in 2008, and you closed the finished tipping mill in Malaucène,
France in the fourth quarter of 2009 (page 25).  We further note your disclosure of the
sales decreases resulting from these actions  on pages 31 and 34.  Please tell us if the
coated papers business or either of the mills represents a component of the entity, as defined in ASC 205-20-20 (formerly paragraph 41 of SFAS 144).  If so, also explain
to us how you considered the guidance in ASC 205-20-45-1 (formerly paragraph 42
of SFAS 144) and ASC 205-20-50-4, 50-6, and 55-4 through 55-24 (formerly EITF
03-13) in determining that none  of these actions represents a disposal that should be
reported as discont inued operations.
 Outlook, page 42

 Lower Ignition Propensity Ci garette Papers, page 43

 3. We note that the Company filed a patent  infringement action on February 8, 2010
against four defendants alleging infringement  of the Company’s United States Patent
Number 6,725,867 and that such adversarial proceedings present uncertainties and
risks, which could include invalidation of th e patent in dispute, a change in the scope
of the patent claims, or an adverse dete rmination on the question of infringement,

Mr. Frederic Villoutreix
Schweitzer-Mauduit International, Inc.
May 27, 2010
Page 3

among others.  Please tell us how you consid ered the MD&A, subsequent events and
commitments and contingencies disclosure requi rements, as applicable, for this patent
infringement action and the rela ted risks and uncertainties.
 Glossary of Terms, page 98

 4. We note in your definition of “Adjusted EBITDA” that one of the items you deduct
from net income is loss from equity a ffiliates.  Based on your  reconciliation to
Adjusted EBITDA on page 24, it appears to us that you do not adjust for income (loss) from equity affiliates.  Pleas e revise your definition or advise.
 Exhibits

 5. We note the discussion on page three and el sewhere that you are th e sole supplier of
on-line banded cigarette papers for use in LI P cigarettes to Phillip Morris-USA for its
U.S. requirements.  It was unclear to us wh ether this agreement had been filed or was
included as part of your Fine Papers Supply Agreement.  If  so, please advise.  If not,
please advise what consideration you gave to Item 601(b)(10) of Regulation S-K as it
relates to this agreement.
 Schedule 14A, filed March 8, 2010

 General

 6. We note your disclosure in response to Item 402(s) of Regulation S-K.  Please
describe the process you undertook to reach the conclusion that disclosure is not
necessary.
 Comprehensive Compensation Di scussion & Analysis, page 13

 7. It was unclear to us why your Grants of Plan-Based Awards table did not contain a
column reporting grant date fair value or how  this disclosure reconciled back to your
2009 Summary Compensation Table. For exampl e, we were unable to tell where the
$3.5 million stock award to Mr. Villoutreix was presented in the table.  Please advise.
  As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.    Please furnish a cover letter that keys
your responses to our comments and provide s any requested information or proposed
disclosure.  Detailed cover letters greatly faci litate our review.  Plea se understand that we
may have additional comments after reviewing your responses to our comments.    We urge all persons who are responsi ble for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its

Mr. Frederic Villoutreix
Schweitzer-Mauduit International, Inc.
May 27, 2010
Page 4

management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
 In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     You may contact Brian McAllister at ( 202) 551-3341 or Dave Walz at (202) 551-
3358 if you have questions regarding comments on the financial statements and related
matters. Please contact Jay Williamson at  (202) 551-3393 with any other questions.

Sincerely,

John Reynolds Assistant Director