SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

         June 22, 2011
 Via Facsimile

Mr. Christopher J. Klein President and Chief Executive Officer Fortune Brands Home & Security LLC 520 Lake Cook Road Deerfield, IL 60015-5611
 Re: Fortune Brands Home & Security LLC
  Amendment 1 to Registration Statement on Form 10   Filed June 15, 2011
 File No. 1-35166

Dear Mr. Klein:

We reviewed your filing and have the following comments.  Please respond to this letter
within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not be lieve an amendment is appropriate, please tell
us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Fractional Shares, page 14

 1. Please refer to prior comment 2 in our lette r dated June 2, 2011.  Delete also the word
“generally” here.
 Selected Financial Data, page 18

 2. Your disclosures throughout the filing present pro forma amounts calculated in two different
ways, which could be confusing to readers.  Please revise your fili ng here and throughout
wherever pro forma amounts are presented to  clarify which pro forma amounts are being
presented.  It could be helpful if the pro fo rma presentation starting on page 98 included a
separate column for the pro forma adjustments to  the income statement and balance sheet that
are necessary to arrive at the pro forma amount s presented alongside the historical financial

Mr. Christopher J. Klein
June 22, 2011 Page 2
 statements starting on page F-3.  This column  could be followed by a “pro forma subtotal”
column and then present anot her column for “other pro forma adjustments” followed by a
“pro forma as adjusted” column.  Such a pr esentation would distinguish the different pro
forma amounts from each other when they are referred to elsewhere in the filing because different captions would be used.
3. Please revise your discussion of MD&A and fina ncial statements in the second paragraph on
page 18 to address also the pro forma financia l information that begins on page 98 and the
capitalization table on page 42.  Please refer to Instruction 2 to Item 301 of Regulation S-K.
 Intellectual property, page 50

 4. Please disclose the information that you gave us in response to comment 6 in our letter dated
June 2, 2011:  “…although each of the Company’ s segments relies on a number of patents
and patent group that, in the aggregate, provi de important protecti ons to the Company, no
patent or group of patents is material  to any of the Company’s segments.”

Unaudited Pro Forma Consolidated Financial Statements, page 98

 5. We note your response to comment 10 from our  letter dated June 2, 2011 and understand that
the terms of your loan agreements are not ye t finalized.  We await the revisions to your
filing, as requested in our prior comment, once they are finalized.

Notes to Unaudited Pro Forma Consolidate Financial Statements, page 103

 6. Please revise your discussion of adjustment (a ) to disclose how you co mputed the amount of
your pro forma interest expense adjustments to  arrive at factually supportable amounts.
 Unaudited Pro Forma Consolidated Balance Sheet, page 102

 7. Please revise your presentation here as well as  on pages 42, F-4, and F-37 to disclose the
historical and pro forma number of shares au thorized, issued, and outstanding.  Please also
revise your presentation here and on pages F- 4 and F-37 to include a separate line item for
common stock since the par value of common stock at least on a pro forma basis is $0.01 per
share.

Mr. Christopher J. Klein
June 22, 2011 Page 3
 Closing

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 in cludes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to the company’s disclosure, they are responsible for the accuracy and adequacy of
the disclosures they have made.   In responding to our comments, please provide, in writing, a statement 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 a ny action with resp ect to the filing.

 The company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
  You may direct questions on accounting commen ts to Lisa H. Ethe redge at (202) 551-
3424 or Rufus G. Decker at (202) 551-3769.  You may direct questions on other comments and
disclosure issues to Edward M. Kelly (202)  551-3728 or Craig E. Slivka at (202) 551-3729.

       Very truly yours,
        / s /  C r a i g  S l i v k a ,  f o r          Pamela A. Long        A s s i s t a n t  D i r e c t o r