SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

         July 18, 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 2 to Registration Statement on Form 10   Filed July 7, 2011
 File No. 1-35166

Dear Mr. Klein:

We reviewed the filing and have the comments below.
 Equity Grants Following the Distribution, page 70

 1. Please revise to disclose the amounts and types of equity-based awards that you expect to
grant on the distribution date or shortly thereafter as well as th e terms associated with these
awards.  We may have further comments once we review your revised disclosure.
 Unaudited Pro Forma Consolidated Financial Statements, page 98

 2. We note your response to comment two from our letter dated June 22, 2011; however, we
believe that the presentation remains a bit conf using to readers.  For example, on page 100,
you use the term “pro forma” interchangeably to  describe loss per ba sic and diluted common
share before and after adjustments.  It woul d be helpful if your pro forma consolidated
statement of income included the same types of columns as the pro forma consolidated
balance sheet so that it is cl ear that the ($0.08) per share pres ented in the far left column on
page 100 represents unadjusted pro forma loss per basic and diluted common share while the
amount that will be presented in the far right column of the same line item on page 100 represents the adjusted pro forma loss per ba sic and diluted common sh are.  As a related
matter, since you seem to describe both una djusted pro forma amounts and adjusted pro
forma amounts interchangeably throughout the fili ng as “pro forma” amo unts, please revise

Mr. Christopher J. Klein
July 18, 2011 Page 2
 your filing throughout to clearly differentiate be tween the unadjusted and adjusted pro forma
amounts to eliminate any potential confusion.
 Condensed Consolidated Statements of Income, page F-36

 3. Please note the updating requirements of Rule 3-12 of Regulation S-X.
 Closing

As appropriate, please amend your filing a nd respond to these comments within 10
business days or tell us when you will provide us with a response.  You may wish to provide us
marked copies of the amendment to expedite our review.  Please furnish a cover letter with your
amendment that keys your res ponses to our comments and provide s any requested information.
Detailed cover letters greatly facilitate our review.  Please understa nd that we may have
additional comments after reviewing your amendment and responses to our comments.   We urge all persons who are responsible for the 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 registra nt and its management are in possession of all
facts relating to the registrant’s disclosure, they  are responsible for the accuracy and adequacy of
the disclosures they have made.

 In connection with responding to our comme nts, please provide, in writing, a statement
acknowledging that:
 The registrant is responsible for the ade quacy 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 registrant may not assert staff co mments as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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 sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.

 You may direct questions on accounting commen ts to Lisa H. Ethe redge at (202) 551-

Mr. Christopher J. Klein
July 18, 2011 Page 3
 3424 or Rufus G. Decker at (202) 551-3769.  You may direct questions on other comments and
disclosure issues to Edward M. Kelly at ( 202) 551-3728 or Craig E. Slivka at (202) 551-3729.
        Very truly yours,         / s /  C r a i g  E .  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