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SEC Company Response from Fortune Brands Innovations, Inc. (FBIN) (CIK 0001519751) (FBIN) — Aug 31, 2011

Fortune Brands Innovations, Inc. (FBIN) (CIK 0001519751)
Date: Aug. 31, 2011 · CIK: 0001519751 · Accession: 0001193125-11-238106

Offering / Registration Process

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 31, 2011
Author
Assistant Secretary
Form
CORRESP
Company
Fortune Brands Innovations, Inc. (FBIN) (CIK 0001519751)

Letter

VIA EDGAR FILING AND OVERNIGHT DELIVERY United States Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing and Construction Washington, DC 20549-4631 Re: Fortune Brands Home & Security, Inc. Registration Statement on Form 10 File No. 1-35166

Dear Ladies and Gentlemen,

In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended (the “Act”), Fortune Brands Home & Security, Inc. (the “Company”) hereby respectfully requests that the effective date of its Registration Statement on Form 10 (File No. 1-35166) be accelerated by the Securities and Exchange Commission (the “Commission”) to 9:00 a.m., New York City time, on September 2, 2011, or as soon thereafter as practicable.

The Company hereby acknowledges that:

•

should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform Lauren S. Tashma at (847) 484-4443, with written confirmation sent to the address listed on the cover of the Registration Statement.

Very truly yours,
Fortune Brands Home & Security, Inc.

Show Raw Text
CORRESP
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filename1.htm

Acceleration Request

 August 31, 2011

 VIA EDGAR FILING 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

Re:
Fortune Brands Home & Security, Inc.

Registration Statement on Form 10

File No. 1-35166

 Dear Ladies and
Gentlemen,

 In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended (the
“Act”), Fortune Brands Home & Security, Inc. (the “Company”) hereby respectfully requests that the effective date of its Registration Statement on Form 10 (File No. 1-35166) be accelerated by the Securities and
Exchange Commission (the “Commission”) to 9:00 a.m., New York City time, on September 2, 2011, or as soon thereafter as practicable.

 The Company hereby acknowledges that:

•

 should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it
does not foreclose the Commission from taking any action with respect to the filing;

•

 the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

 the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

 It would be appreciated if, as soon as the
Registration Statement is declared effective, you would so inform Lauren S. Tashma at (847) 484-4443, with written confirmation sent to the address listed on the cover of the Registration Statement.

Very truly yours,

Fortune Brands Home & Security, Inc.

By:

 /s/ Lauren S. Tashma

Name:

Lauren S. Tashma

Title:

Assistant Secretary