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Correspondence

 June 15, 2011

 VIA EDGAR SUBMISSION AND OVERNIGHT DELIVERY

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Manufacturing and Construction

 100 F Street, N.E.

Washington, DC 20549-4631

          Attention: Pamela A. Long, Assistant Director

Re:
Fortune Brands Home & Security LLC

 Amendment No. 1 to Registration Statement on Form 10

 File No. 1-35166

 Dear Ms. Long:

Fortune Brands Home & Security LLC, a Delaware limited liability company (the “Company”), has today filed with the
Securities and Exchange Commission (the “Commission”) Amendment No. 1 to the Company’s Registration Statement on Form 10, File No. 1-35166 (the “Amendment”), relating to the spin-off of the Company from Fortune
Brands, Inc.

 We are writing to respond to the comments raised in the staff’s letter to the Company dated June 2,
2011. The responses below correspond to the captions and numbers of those comments (which are reproduced below in italics). For your convenience, three copies of the Amendment are enclosed and have been marked to show changes to the Company’s
Registration Statement on Form 10, as originally filed with the Commission on May 6, 2011. References to page numbers in our responses are to page numbers of the preliminary information statement, which is filed as Exhibit 99.1 to the Amendment
(the “Information Statement”). Capitalized terms used but not defined in this letter have the meanings assigned to them in the Information Statement.

 We acknowledge the following:

•

 the Company is responsible for the adequacy and accuracy of the disclosures in the filing;

•

 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.

 General

1.
Please tell us whether the distribution agent and the broker-dealers it will use to sell fractional shares are affiliates of Fortune Brands or Home &
Security. Please also confirm that the distribution agent will, in its sole discretion (that is, without influence by Fortune Brands or Home & Security), determine when, how, through which broker-dealer, and at what price to make its sales
of fractional shares.

 Response: The Company supplementally informs the staff that neither the distribution
agent (Wells Fargo Shareowner Services) nor any of the broker-dealers that will be used to sell whole shares of Home & Security common stock in order to distribute cash proceeds in lieu of fractional shares of Home & Security
common stock are affiliates of either Fortune Brands, Inc. or the Company. Further, the Company supplementally confirms that the distribution agent will, in its sole discretion, determine when, how, through which broker-dealer and at what price to
make its sales of Home & Security common stock in order to distribute cash proceeds in lieu of fractional shares of Home & Security common stock.

 Q: What are the U.S. federal income tax consequences, page 9

2.
Delete the word “generally” in the second paragraph’s last sentence because the word may imply that you have not disclosed all material United States
federal income tax consequences and that investors cannot rely on the disclosure. Similarly, delete the word “generally” in the last bullet point statement on page 37.

Response: We have deleted the word “generally” from the disclosure in response to this comment. See pages 9 and 37.

 Risk Factors, page 20

3.
We note the statements “However, the risks and uncertainties we face are not limited to those described below. Additional risks and uncertainties not presently
known to us or that we currently believe to be immaterial may also materially adversely affect our results of operations, cash flows and financial condition.” Since Fortune Brands Home & Security is required to disclose all
risks that it believes are material at this time, please delete these statements.

 Response:
We have deleted the statement “However, the risks and uncertainties we face are not limited to those described below. Additional risks and uncertainties not presently known to us or that we currently believe to be immaterial may also materially
adversely affect our results of operations, cash flows and financial condition” in response to this comment. See page 20.

 Cautionary
Statement Concerning Forward-Looking Statements, page 32

4.
We note the phrase “within the meaning of the Private Securities Litigation Reform Act of 1995.” Fortune Brands Home & Security is ineligible to
rely on the Act’s safe harbor provision because the distribution is in essence its initial public offering. Please delete the phrase. Alternatively, revise the disclosure to make clear that Fortune Brands Home & Security is ineligible
to rely on the Act’s safe harbor provision. See Section 21E(b)(2)(D) of the Exchange Act.

Response: We have deleted the phrase “within the meaning of the Private Securities Litigation Reform Act of 1995” in response to
this comment. See page 32.

 Business, page 43

5.
Disclose the extent to which the business of each segment is or may be seasonal. See Item 101(c)(1)(v) of Regulation S-K.

Response: We have added the disclosure shown below under the heading “Other Information—Seasonality” on page 51.

 Seasonality. All of our operating segments traditionally experience lower
sales in the first quarter of the year when new home construction, repair-and-remodel activity and security and storage buying are lowest. As a result of sales seasonality and associated timing of working capital fluctuations, our cash flow from
operating activities is typically higher in the second half of the year.

 Intellectual property, page 50

6.
Disclose the duration of all patents held by Fortune Brands Home & Security. See Item 101(c)(1)(iv) of Regulation S-K.

 Response: The Company respectfully submits that the disclosure of the duration of all patents held by
Home & Security is not necessary under Item 101(c)(1) of Regulation S-K, because no patent or group of patents is material to an understanding of Home & Security’s business taken as a whole. In addition, the Company
supplementally notes that, although each of the Company’s segments relies on a number of patents and patent groups that, in the aggregate, provide important protections to the Company, no patent or group of patents is material to any of the
Company’s segments.

 Equity Grants Following the Distribution, page 70

7.
Please disclose whether you will grant equity-based awards to Fortune Brand [sic] employees who will not be employees of Home & Security after the spin-off.

 Response: We have revised the disclosure as follows:

Equity Grants Following the Distribution

 On the Distribution Date or shortly thereafter, we expect to grant equity-based awards to Home & Security named executive officers and a small number of other Home & Security executive
officers and Home & Security key employees. We expect that each of these awards would consist of both Home & Security RSUs and Home & Security options. The amounts and types of these awards will be determined prior to the
effective date of the Form 10 registration statement of which this Information Statement forms a part. Following the Separation, Home & Security will not grant equity-based awards to any employees of Fortune Brands.

Description of Capital Stock, page 94

8.
We note the reference to the Delaware General Corporate Law and the “qualified in its entirety” language. You may not qualify information in the
registration statement by reference to information outside the registration statement unless incorporation by reference or a summary of a document filed as an exhibit is required by the form. See Rule 12b-23 of the Exchange Act, and revise.

 Response: We have deleted the reference to the Delaware General Corporate Law and the “qualified in
its entirety” language in response to this comment. See page 93.

 Unaudited Pro Forma Consolidated Financial Statements, page 99

9.
Please clarify for readers which additional adjustments have been made in these pro forma financial statements as compared to the pro formas presented alongside your
historical financial statements.

 Response: We have added the following as the last paragraph on page 98 as
shown below:

 The unaudited pro forma consolidated balance sheet as of March 31, 2011 contained in this section differs
from the unaudited pro forma consolidated balance sheet presented with our historical financial statements contained elsewhere in this Information Statement. The unaudited pro forma consolidated balance sheet presented with our historical
financial statements contains pro forma adjustments limited to those required by SEC Staff Accounting Bulletin Topic 1:B-3 which (i) give effect to the capitalization into equity of all loans between the Company and Fortune Brands and the
payment by the Company of a $500 million dividend immediately prior to the Distribution and (ii) include the retained deficit as additional paid in-capital in accordance with SEC Staff Accounting Bulletin Topic 4:B.

10.
Please revise note (b) on page 103 and your disclosures elsewhere in the filing to describe the terms of your loans and loan commitments. Please also revise the
footnote to show how you computed the pro forma interest expense recorded for each period presented. If actual interest rates in the transaction can vary from those depicted, disclosures of the effect on income of a 1/8 percent variance in the
interest rates should also be provided.

 Response: We have not finalized our loan and
loan commitments (“Loan Agreements”). We expect that the terms of our Loan Agreements will be finalized prior to the effective date of the Registration Statement on Form 10. Once finalized, we intend to disclose the terms of the Loan
Agreements in an amendment to the Form 10 filed prior to effectiveness, and, if appropriate, we will include in that amendment the effect on income of a 1/8th percent variance in interest rates.

 Management’s Discussion and Analysis of Financial Condition and Results of Operations

2010 Compared to 2009, page 108

11.
Please revise your MD&A throughout as necessary to separately quantify the impact of each factor affecting your operating results. Alternatively, where only
certain amounts can be quantified, please revise to more clearly indicate the specific factors to which your quantification pertains. For example, you disclose on page 109 that net sales for the Kitchen & Bath Cabinetry segment increased on
higher sales volume due to new business wins and new products introductions as well as favorable foreign exchange. You quantified an amount of $20 million; however, it is unclear if this amount is intended to represent only the impact of the
favorable foreign exchange or the impact of all of the factors referenced in that sentence.

 Response: We
have revised the disclosure in response to this comment.

 Contractual Obligations, page 116

12.
Please discuss in this section just below the contractual obligations table the $500 million loan that you will enter into to pay the $500 million dividend to
Fortune Brands and that it is not included in the table. Please also disclose here the approximate annual interest expense on this loan and that it is not included in the table either.

Response: We have revised the disclosure in response to this comment. In a paragraph below the Contractual Obligations table, we have
added the following language:

 Prior to the Distribution, we expect to pay a $500 million dividend to Fortune Brands. In
connection with this dividend, we expect to incur approximately $500 million of debt prior to or on the Distribution Date. The interest expense on this loan is expected to be approximately $[•] million on an annual basis. Neither the debt nor
the interest expense is included in the Contractual Obligations table above.

 Index to Financial Statements, page F-1

13.
Please note the updating requirements of Rule 3-12 of Regulation S-X.

 Response: We have updated the financial statements and financial information throughout the document pursuant to Rule 3-12 of Regulation S-X.

 3

14.
To the extent that a stock split has occurred or is expected to occur prior to effectiveness, please disclose this and give retroactive effect to it throughout the
filing, including your historical financial statements as required by SAB Topic 4:C. Doing this in the next amendment will save us substantial review time in future amendments. If your auditors believe that only a “draft” report can be
presented due to a pending future event such as the stock split, they may include in the filing a signed and dated preface to their “draft” report stating the reason for the “draft” report and that they expect to be in a position
to issue the report in the form presented prior to effectiveness. A signed, dated, and unrestricted auditor’s report must be included in the filing prior to effectiveness. Refer to Rule 2-02 of Regulation S-X.

 Response: A stock split has not occurred nor is it expected to occur prior to the effectiveness of the
Registration Statement on Form 10. Accordingly, we have not given retroactive effect to the stock split in the Information Statement.

Report of Independent Registered Public Accounting Firm, page F-2

15.
Please have your auditors revise their opinion to indicate the city and state where the opinion was issued. Please refer to Rule 2-02(a) of Regulation S-X.

 Response: The auditors have revised their opinion to indicate the city and state where the opinion was issued.
See page F-2.

 Consolidated Statements of Income, page F-3

16.
Please present historical diluted earnings per share here and elsewhere throughout the filing. If historical basic and diluted earnings per share are
the same, then revise the title to so indicate. Please also present basic pro forma earnings per share here and elsewhere throughout the filing.

 Response: We have revised the Information Statement to present historical diluted earnings per share and basic pro forma earnings per share on the Consolidated Statements of Income and elsewhere
throughout the Information Statement. We have also revised the title, as appropriate, to reflect that historic basic and diluted earnings per share are the same.

 Consolidated Balance Sheets, page F-4

17.
On page 33, you indicate that prior to effectiveness you will be converted from a limited liability company to a C corporation. Please revise your pro forma retained
deficit and paid-in capital line items accordingly. Please also revise Note 17 and page 102. Refer to SAB Topic 4:B.

 Response: We have revised the pro forma Consolidated Balance Sheets to include the retained deficit as additional paid-in capital in accordance with SAB Topic 4:B. See pages 102, F-4 and F-37.

Note 1. Background and Basis of Presentation

 Inventories, page F-8

18.
Please disclose for your LIFO inventory the excess of replacement or current cost over stated LIFO value. Refer to Rule 5-02.6(c) of Regulation S-X.

 Response: We have disclosed the excess of replacement or current cost over
stated LIFO value. See the second paragraph of the Inventories section on page F-8.

 Note 15. Information on Business Segments, page F-30

19.
Please separately disclose the total amount of revenues for each customer that accounted for 10% or more of your revenues rather than presenting only aggregated
information. Please also tell us what consideration you gave to providing the disclosures regarding concentrations required by ASC 275-10-50-16 to 50-20, including, but not limited to, the loss of a significant customer.

 Response: We have revised our disclosure on page F-30 with respect to revenues for each customer that accounted
for mo