SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

        October 28, 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.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Mr. Frederic Villoutreix
Schweitzer-Mauduit International, Inc.
October 28, 2010
Page 2

Schedule 14A, filed March 8, 2010
 1. We note your responses to prior comments three and four from our letter dated
September 21, 2010.  In your response to comm ent four you state you “will revise [y]our
future disclosures to disclose the award ear n-out deemed most probable as of the Grant
Date for all years of an award cycle calc ulated in accordance w ith FASB ASC Topic 718
in both Column (e) of the Summary Compensati on Table and Column (l) of the Grants of
Plan Based Awards table, as set forth in the pr o-forma tables attached …”  In footnote (1)
to the proposed tables, you describe the re ported amount as an “estimate of the award
value deemed most probable to be earned in the 2009-2010 award cycle calculated in
accordance with FASB ASC Topic 718 ….”
   We are unclear whether your measurement
agrees with the measurement in Instruction 3 to Item 402(c)(2)(v) and (vi) which says a
registrant should report the value of an awar d at the grant date based upon the probable
outcome of performance conditions.  Please explain or revise.

2. We note the large differences between the value of the stock awards in  your most recent
proposed Grants of Plan Based Awards tabl e and the prior values included in the
Schedule 14A and the September 10, 2010 response  letter.  Please expl ain the reasons for
the differences in these amounts.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
You may contact Brian McAllister at (202) 551-3341 or Dave Walz at (202) 551-3358 if
you have questions regarding comments on the fi nancial statements and related matters. Please
contact Jay Williamson at (202) 551 -3393 with any other questions.

Sincerely,

John Reynolds Assistant Director