SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

          August 30, 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
  Amendments 4 and 5 to Registration Statement on Form 10   Filed August 22 and 26, 2011
 File No. 1-35166

Dear Mr. Klein:

We reviewed the filings and have the comment below.
 Exhibit 10.6

 1. We note that you did not file the schedules and exhibits to the credit  agreement filed as
exhibit 10.6.  Unlike Item 601(b)(2) of Regul ation S-K, there is no provision in Item
601(b)(10) of Regulation S-K for excluding schedule s or similar attachments.  Please refile
the complete credit agreement, including its schedules and exhibits.
 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 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.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

Mr. Christopher J. Klein
Fortune Brands Home & Security, Inc. August 30, 2011 Page 2
  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 federa l securities 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 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