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CORRESP
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October 31,
2008

Mr. John Reynolds

Assistant Director

United States Securities
and Exchange Commission

450 Fifth Street

Washington, D.C.  20549-0405

  Re:

  Response
  of Schweitzer-Mauduit International, Inc.

  to
  Comment Letter from the Securities and Exchange

  Commission
  dated October 15, 2008

  Commenting
  on Form 10-K/A for Fiscal Year Ended December 31, 2007

  Filed October 7, 2008

  Definitive
  Proxy Statement on Schedule 14A

  Filed
  March 7, 2008

  File
  No. 001-13948

Dear Mr. Reynolds:

Attached is
the response of Schweitzer-Mauduit International, Inc. (the “Company” or “registrant”
or “SWM”) to the Securities and Exchange Commission’s (the “Commission” or “Staff”)
comment dated October 15, 2008 to the Company’s Form 10-K/A filed October 7,
2008 in connection with its response dated October 8, 2008 in conjunction
with the original comment letter from the Commission dated July 1, 2008 on
the above identified disclosure documents filed by the Company. We have
attempted to fully respond and to provide information that would assist in more
fully understanding our disclosures.

The
Company’s response to the Commission’s comment follows as set forth in your October 15,
2008 letter.

Form 10-K/A for Fiscal Year Ended December 31,
2007

Certifications required under Rules 13a-14(a) and
15d–14(a) of the Securities Exchange Act of 1934

1.                                       We
note that you did not file new Section 302 certifications with the
amendment.  Please file new Section 302
certifications.  See SEC Release Nos.
33-8238; 34-47986, which is available at:
http://www.sec.gov/rules/final/33-8238.htm.

Response:  In response to this comment, we have drafted
Amendment No. 2 to our
Form 10-K for the year-ended December 31, 2007, which
incorporates new Section 302 certifications.  Please review the attached draft
filing, and if it is acceptable to you, we will file the document as resolution
to this matter.

We
are hopeful that this letter resolves the Staff’s concerns with regard to this
comment.  If it does not, we would appreciate the
opportunity to discuss the comment with you.
Please call me at (770) 569-4278 to arrange for a mutually convenient
time to discuss the Company’s response and any additional questions that the
Commission may have.

  Sincerely,

  /s/John W.
  Rumely, Jr.

  John W.
  Rumely, Jr.

  General Counsel

CC:  David Link, Division of Corporation Finance

DRAFT

UNITED
STATES

SECURITIES AND
EXCHANGE COMMISSION

Washington,
D.C. 20549

FORM 10-K/A

(Amendment No. 2)

(Mark One)

  x

  ANNUAL
  REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
  ACT OF 1934

  For
  the fiscal year ended December 31, 2007

  OR

  o

  TRANSITION
  REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
  ACT OF 1934

For the transition
period from

to

1-13948

(Commission file number)

SCHWEITZER-MAUDUIT INTERNATIONAL, INC.

(Exact name of registrant
as specified in its charter)

  Delaware

  62-1612879

  (State or other jurisdiction of

  (I.R.S. Employer

  incorporation or organization)

  Identification No.)

  100 North Point Center East,
  Suite 600

  Alpharetta, Georgia

  30022-8246

  (Address of principal executive offices)

  (Zip Code)

1-800-514-0186

(Registrant’s
telephone number, including area code)

Securities Registered Pursuant to Section 12(b) of the Act:

  Title of each class

  Name of exchange on which registered

  Common stock, par value $0.10 per share

  New York Stock Exchange, Inc.

  (together with associated preferred stock purchase
  rights)

Securities
Registered Pursuant to Section 12(g) of the Act: None

Indicate by check
mark if the registrant is a well-known seasoned issuer, as defined by Rule 405
of the Securities Act.  Yes x
No o

Indicate by check
mark if the registrant is not required to file reports pursuant to Section 13
or Section 15(d) of the Act.
Yes x No o

Indicate by check
mark whether the registrant: (1) has filed all reports required to be
filed by Section 13 or 15(d) of the Securities Exchange Act of 1934
during the preceding 12 months (or for such shorter period that the
registrant was required to file such reports), and (2) has been subject to
such filing requirements for the past 90 days. Yes x
No o

Indicate by check
mark if disclosure of delinquent filers pursuant to Item 405 of
Regulation S-K is not contained herein, and will not be contained, to the
best of registrant’s knowledge, in definitive proxy or information statements
incorporated by reference in Part III of this Form 10-K or any
amendment to this Form 10-K. o

   Indicate by check mark whether the registrant is a
large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller
reporting company. See definitions of “large accelerated filer,” “accelerated
filer,” and “smaller reporting company” in Rule 12b-2 of the Exchange Act.
(Check one):

  Large
  accelerated filer o

  Accelerated
  filer x

  Non-accelerated
  filer o

  Smaller
  reporting company o

  (Do not check if a smaller

  reporting company)

Indicate by check
mark whether the registrant is a shell company (as defined in Rule 12b-2
of the Exchange Act).  Yes o
No x

   The
aggregate market value of the outstanding common stock, par value $0.10 per
share (the “Common Stock”), held by non-affiliates of the registrant as of June 29,
2007 (the last business day of the registrant’s most recently completed second
fiscal quarter) was $480.7 million, based on the last sale price for the Common
Stock of $31.00 per share as reported on the New York Stock Exchange on said
date. For purposes of the foregoing sentence only, all directors and executive
officers are assumed to be affiliates.

There were
15,491,609 shares of Common Stock issued and outstanding as of February 29,
2008.

DOCUMENTS
INCORPORATED BY REFERENCE

Portions of the
Registrant’s definitive Proxy Statement relating to its 2008 Annual Meeting of
Stockholders scheduled to be held on April 24, 2008 (“the 2008 Proxy
Statement”) and filed pursuant to Regulation 14A are incorporated by reference
into Part III of this Form 10-K.

DRAFT

EXPLANATORY
NOTE

This Second Amendment is
being filed solely to include the Certifications of the Chief Executive Officer
and Chief Financial Officer pursuant to Section 302 of the Sarbanes-Oxley
Act of 2002 to the First Amendment, which was filed with the Securities and
Exchange Commission on October 7, 2008, and incorporated by reference the
Proxy Statement’s “Comprehensive Compensation Discussion and Analysis” in Part III.,
Item 11, Executive Compensation, of our Annual Report on Form 10-K, and
does not amend or update any other part of that annual report.

DRAFT

PART III.

Item 11.  Executive Compensation

The
information in the section of the 2008 Proxy Statement captioned “Executive
Compensation,” including the item captioned “Comprehensive Compensation
Discussion and Analysis,” is incorporated in this Item 11 by reference.

DRAFT

PART 1V.

3. Exhibits

  Exhibit

  Number

  Exhibit

  * 31.1

  Certification of the Chief
  Executive Officer pursuant to Section 302 of the Sarbanes-Oxley Act of
  2002.

  * 31.2

  Certification of the Chief
  Financial Officer pursuant to Section 302 of the Sarbanes-Oxley Act of
  2002.

* Filed herewith.

DRAFT

SIGNATURES

Pursuant to the
requirements of Section 13 or 15(d) of the Securities Exchange Act of
1934, the registrant has duly caused this report to be signed on its behalf by
the undersigned, thereunto duly authorized.

  SCHWEITZER-MAUDUIT INTERNATIONAL, INC.

  By:

  /s/ WAYNE H. DEITRICH

  Wayne H. Deitrich

  Chairman of the Board and

  Chief Executive Officer

  Dated: November x, 2008

  (principal executive officer)

Pursuant
to the requirements of the Securities Exchange Act of 1934, this report has
been signed below by the following persons on behalf of the registrant and in
the capacities and on the dates indicated.

  Name

  Position

  Date

  /s/WAYNE H. DEITRICH

  Chairman of the Board and

  November x, 2008

  Wayne H. Deitrich

  Chief Executive Officer

  (principal executive officer)

  /s/TORBEN WETCHE

  Chief Financial Officer

  November x, 2008

  Torben Wetche

  and Treasurer

  (principal financial officer)

  /s/MARK A. SPEARS

  Controller

  November x, 2008

  Mark A. Spears

  (principal accounting officer)

  *

  Chief Operating Officer

  November x, 2008

  Frédéric P. Villoutreix

  Director

  *

  Director

  November x, 2008

  Claire L. Arnold

  *

  Director

  November x, 2008

  K.C. Caldabaugh

  *

  Director

  November x, 2008

  William Finn

  *

  Director

  November x, 2008

  Richard D. Jackson

  *

  Director

  November x, 2008

  Robert F. McCullough

  *By:

  /s/JOHN W. RUMELY, JR.

  November x, 2008

  John W. Rumely, Jr.

  Attorney-In-Fact

DRAFT

EXHIBIT
31.1

CERTIFICATION OF CHIEF EXECUTIVE OFFICER

PURSUANT TO SECTION 302 OF THE
SARBANES-OXLEY ACT OF 2002

I, Wayne H. Deitrich, certify that:

1.               I have reviewed the report on Form 10-K/A
of Schweitzer-Mauduit International, Inc. (the “Registrant”);

2.               Based on my knowledge, this report does not contain any untrue statement
of a material fact or omit to state a material fact necessary to make the
statements made, in light of the circumstances under which such statements were
made, not misleading with respect to the period covered by this report;

3.               The Registrant’s other certifying officer and I are responsible for
establishing and maintaining disclosure controls and procedures (as defined in
Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over
financial reporting (as defined in Exchange Act Rules 13a-15(f) and
15d-15(f)) for the Registrant and have:

a)              Designed such disclosure controls and procedures, or caused such
disclosure controls and procedures to be designed under our supervision, to
ensure that material information relating to the Registrant, including its
consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

b)             Designed such internal control over financial reporting, or caused such
internal control over financial reporting to be designed under our supervision,
to provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles.

4.               The Registrant’s other certifying officer and I have disclosed, based on
our most recent evaluation of internal control over financial reporting, to the
Registrant’s auditors and the audit committee of the Registrant’s board of
directors (or persons performing the equivalent functions):

a)              All significant deficiencies and material weaknesses in the design or
operation of internal control over financial reporting which are reasonably
likely to adversely affect the Registrant’s ability to record, process,
summarize and report financial information; and

b)             Any fraud, whether or not material, that involves management or other
employees who have a significant role in the Registrant’s internal control over
financial reporting.

Date:  November x, 2008

  Wayne
  H. Deitrich

  Chairman
  of the Board and

  Chief
  Executive Officer

A signed original of this
written statement required by Section 302 of the Sarbanes-Oxley Act of
2002 has been provided to the Company and will be retained by the Company and
furnished to the Securities and Exchange Commission or its staff upon request.

DRAFT

EXHIBIT
31.2

CERTIFICATION OF CHIEF EXECUTIVE OFFICER

PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY
ACT OF 2002

I, Torben Wetche, certify that:

1.               I have reviewed the report on Form 10-K/A
of Schweitzer-Mauduit International, Inc. (the “Registrant”);

2.               Based
on my knowledge, this report does not contain any untrue statement of a
material fact or omit to state a material fact necessary to make the statements
made, in light of the circumstances under which such statements were made, not
misleading with respect to the period covered by this report;

3.               The
Registrant’s other certifying officer and I are responsible for establishing
and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and
15d-15(e)) and internal control over financial reporting (as defined in
Exchange Act Rules 13a-15(f) and 15d-15(f)) for the Registrant and
have:

a)              Designed
such disclosure controls and procedures, or caused such disclosure controls and
procedures to be designed under our supervision, to ensure that material
information relating to the Registrant, including its consolidated
subsidiaries, is made known to us by others within those entities, particularly
during the period in which this report is being prepared;

b)             Designed
such internal control over financial reporting, or caused such internal control
over financial reporting to be designed under our supervision, to provide
reasonable assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in accordance with
generally accepted accounting principles.

4.               The
Registrant’s other certifying officer and I have disclosed, based on our most
recent evaluation of internal control over financial reporting, to the Registrant’s
auditors and the audit committee of the Registrant’s board of directors (or
persons performing the equivalent functions):

a)              All
significant deficiencies and material weaknesses in the design or operation of
internal control over financial reporting which are reasonably likely to
adversely affect the Registrant’s ability to record, process, summarize and
report financial information; and

b)             Any
fraud, whether or not material, that involves management or other employees who
have a significant role in the Registrant’s internal control over financial
reporting.

Date:  November x, 2008

  Torben
  Wetche

  Chief Financial Officer and

  Treasurer

A signed original of this
written statement required by Section 302 of the Sarbanes-Oxley Act of
2002 has been provided to the Company and will be retained by the Company and
furnished to the Securities and Exchange Commission or its staff upon request.