SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 0510

      March 16, 2005

Via U.S. mail and facsimile

David S. McCulloch, Chief Executive Officer
Enodis PLC
2227 Welbilt Boulevard
New Port Richey, FL  34655

	RE:	Form 20-F for the fiscal year ended October 2, 2004
			File No. 1-15032

Dear Mr. McCulloch:

		We have reviewed these filings and have the following
comments.  If you disagree with a comment, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 20-F FOR THE YEAR ENDED OCTOBER 2, 2004

Comment applicable to your overall filing
1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  Some of our comments refer to
US
GAAP literature.  If you accounting under UK GAAP differs from
your
accounting under US GAAP, please also show us the additional
disclosures that will be included in your US GAAP reconciliation
footnote.  These revisions should be included in your future
filings
beginning to the extent practical with your report of Form 6-K
announcing results for the 26 weeks ending about April 2, 2005.

Item 3. Key Information

Selected Financial Data, page 2
2. Since each American Depositary Share (ADS) represents four
ordinary shares, also present per share information on an ADS
equivalent. This information might also be included in Note 28,
Supplementary Information for U.S. Investors.

Item 4. Information on the Company
3. You have disclosed under your product group discussion many
brand
names relating to the products you sell.  Please expand your
disclosure to discuss the importance of brand names to your
business.

Food Service Equipment

End Customers, page 13
4. You have disclosed that no single food service equipment
customer
accounted for over 10% of our total turnover in Fiscal 2004.
Please
expand your disclosure to include whether there is a concentration
of
turnover in a small group of customers.

Environmental Matters, page 22
5. You have disclosed that some of your subsidiaries have been
named
as potential responsible parties with respect to certain sites.
Please expand your disclosure to identify the sites and to include
a
discussion of each site so as to permit an assessment of your
potential exposure.  If material, please expand your disclosure to
include the total amount of expenses related to environmental
matters
recorded in each of the periods presented.  In addition, if
applicable, please include the balance of any accrued amounts at
each
of the balance sheet dates.  Please indicate in your response the
line items in your financial statements for which these amounts
were
recorded.

Item 5. Operating and Financial Review and Prospects

Liquidity and Capital Resources, page 33
6. You have stated in your risk factors on page 8 that some
jurisdictions may restrict the repatriation of your non-U.K.
earnings.  Please expand your disclosure to include any legal
restrictions you currently have regarding the ability or the
ability
your subsidiaries to pay dividends to affiliated companies. The
present disclosure is too generalized to be useful. Any relevant
disclosures contemplated by Rule 4-02(e) of Regulation S-X should
be
made.
7. You have disclosed on page 14, some of your most important new
products.  Please expand your disclosure to include information
relating to the status of new products, your outlook on how these
new
products have impacted or will likely impact your revenue,
margins,
liquidity, capital commitments, and future growth.
8. Please expand your disclosure in future filings to discuss any
recent price increases or decreases and the related impact these
price changes have had or will likely have on your results of
operations, revenue and margins.

Contractual Payment Obligations, page 36
9. Please revise your table of contractual payment obligations to
include estimated interest payments on your debt.  Because the
table
is aimed at increasing transparency of cash flow, we believe these
payments should be included in the table.  Please also disclose
any
assumptions you made to derive these amounts.

Item 8. Financial Information

Dividend Policy, page 53
10. You have disclosed that you did not pay a cash dividend in
either
2004 or 2003, but plan to reinstate the dividend in 2006, subject
to
among other matters, obtaining necessary consents.  In future
filings
please ensure you disclose your progress in removing the
restrictions
and overcoming the other obstacles associated with the
reinstatement
of the dividends for 2006.

Financial Statements

2. Accounting policies, page F-8
11. Please expand your disclosures to include a disclosure that
describes your accounting policy relating to the treatment of
shipping and handling costs, including both costs incurred by you
and
those charged to your customers.  Please include in your response
the
line items that these costs have been recorded in.  Refer to EITF
00-
10.
12. Please expand your disclosures to include how you account for
the
following expenses:
* intellectual property licensed from third parties,
* inbound freight charges,
* purchasing and receiving costs,
* inspection costs,
* warehousing costs,
* internal transfer costs, and
* other costs relating to your distribution network.
Please include in your disclosure which line items these costs are
included in your financial statements.
13. You have disclosed on page F-17 that your property segment
assets
increased 4.0 million (GBP).  In addition, property sales for
fiscal
2004 were 11.4 million (GBP).  Please expand your disclosure to
explain the reason for this increase.  In addition, your
accounting
policy disclosure indicates that your land is stated at cost,
unless
an impairment has occurred.  You have also disclosed on page 18
that
you invest resources in resolving environmental compliance issues
relating to the land prior to selling it.  Please expand your
disclosures to include how these costs are recorded in your
financial
statements.

10.  Tax on profit/(loss) on ordinary activities, page F-23
14. You have disclosed that the expiration of your U.S. losses
will
commence in fiscal 2007 and will continue to expire through 2010
if
unused.  Please expand your disclosure to include the amounts that
you anticipate will expire over each of the next five years and
any
remaining amounts thereafter in total.  In addition to the above,
please expand your disclosure to include the approximate tax
effect
of each type of temporary difference and carrforward that
comprises a
significant portion of the deferred tax liabilities and deferred
tax
assets.  Refer to paragraphs 43 and 48 of SFAS 109.

28. Supplementary Information for U.S. Investors
15. You disclosed on page 7 that you have begun implementing
Enterprise Resource Planning systems at various locations.  If
material, please expand your disclosures for each of the periods
presented to include the following:
* the total amount of internal costs capitalized and the line item
in
your financial statements where this was recorded,
* the total amount of internal costs recorded as expense and the
line
item in your financial statements where this was recorded,
* the amortization expense recorded and the line item in your
financial statements where this was recorded, and
* your accounting policy regarding the types of costs capitalized
and
the amortization method and period.
Refer paragraph 41 of SOP 98-1.
16. You disclosed on page 24 and in Note 21 that in Fiscal 2003
and
you entered into a restructuring program totaling 6.1 million
(GBP).
We acknowledge the analysis of movement in the provisions you have
disclosed in Note 21.  However, your disclosure does not include
the
disclosures required by paragraph 20 of SFAS 146.  Your filing on
Form 6-K for the period ended January 1, 2005 disclosed your
announcement in November 2004 regarding a new restructuring
program
totaling 6.5 million (GBP).  In future filings please include this
information for new restructuring programs entered into.

Consolidated Statements of Cash Flows, page F-54
17. Please expand your disclosure to show reconciliations for the
gross effects for the following that are presented net in your
statements of cash flows:
* Acquisition/disposal of subsidiary undertakings and
* Net decrease in borrowings.
Refer to paragraph 11 of SFAS 95. Please also refer to Items
17(c)(iii) and 18 of Form 20-F.

*    *    *    *

      Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
us
with a supplemental response letter that keys your responses to
our
comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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.

	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 their filings;
* 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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Meagan Caldwell, Staff Accountant, at (202) 824-
5578
or, in her absence, Nathan Cheney, Assistant Chief Accountant, at
(202)942-1804.

							Sincerely,

							Rufus Decker
							Accounting Branch Chief

??

??

??

??

Mr. David S. McCulloch
March 16, 2005
Page 1 of 7

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>